Privacy Policy

Introduction

    1. We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.
    2. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

How we use your personal data

    1. In this Section 2 we have set out:
      1. the general categories of personal data that we may process;
      2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
      3. the purposes for which we may process personal data; and
      4. the legal bases of the processing.
    2. We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
    3. We may process your account data (“account data“). The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
    4. We may process your information included in your personal profile on our website (“profile data“). The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
    5. We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
    6. We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
    7. We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
    8. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
    9. We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
    10. We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    11. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    12. Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Providing your personal data to others

    1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
    2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
    3. We may disclose account data to our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract.
    4. In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Retaining and deleting personal data

    1. This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    3. We will retain and delete your personal data as follows:
      1. account and profile data will be retained for 5 years following initial contact, at the end of which period it will be deleted from our systems.
    4. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
      1. the period of retention of account and profile data will be determined based on whether you continue to rely on our services.
    5. Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Security of personal data

    1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
    2. The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.
    3. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
    4. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
    5. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

Amendments

    1. We may update this policy from time to time by publishing a new version on our website.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
    3. We may notify you of changes to this policy by email.

Your rights

    1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
      1. the payment of a fee (currently fixed at GBP 10); and
      2. the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
    2. We may withhold personal information that you request to the extent permitted by law.
    3. You may instruct us at any time not to process your personal information for marketing purposes.
    4. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

Third party websites

    1. Our website includes hyperlinks to, and details of, third party websites.
    2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Personal data of children

    1. Our website and services are targeted at persons over the age of 18.
    2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

Updating information

    1. Please let us know if the personal information that we hold about you needs to be corrected or updated.

About cookies

    1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

    1. We use cookies for the following purposes:
      1. security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
      2. analysis – we use cookies to help us to analyse the use and performance of our website and services; and
      3. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies used by our service providers

      1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
      2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Managing cookies

      1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
        1. https://support.google.com/chrome/answer/95647?hl=en(Chrome);
        2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences(Firefox);
        3. http://www.opera.com/help/tutorials/security/cookies/(Opera);
        4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);
        5. https://support.apple.com/kb/PH21411(Safari); and
        6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy(Edge).
      2. Blocking all cookies will have a negative impact upon the usability of many websites.
      3. If you block cookies, you will not be able to use all the features on our website.

Our details

      1. This website is owned and operated by BESPOKE CHANGE LTD.
      2. We are registered in England and Wales under registration number 10688429, and our registered office is at 9 De Montfort Street, Leicester LE1 7GE.
      3. You can contact us:
        1. by post, using the postal address given above;
        2. by telephone, on the contact number published on our website; or
        3. by email, using the email address published on our website.

Representative within the European Union

        1. Our representative within the European Union with respect to our obligations under data protection law is Michael Fekete and you can contact our representative by phone or email using the information published on this website.

Data protection officer

        1. Our data protection officer’s contact details are: Michael Fekete using the contact information published on this website.