At Carefree Consultancy Ltd T/A Secure Payment Solutions, your privacy is very important to us and we want to assure you that we take the confidentiality and security of your personal data very seriously. Carefree Consultancy Ltd is a company registered in England.
- What personal data we collect and how we collect it
- Personal data you provide when you purchase from us
- Personal data obtained when you use our website
- Personal data obtained if you contact us
How we use the personal data we collect from you
- To fulfil your order
- For customer care
- For marketing
- For internal business purposes
Our lawful basis for processing your personal data
2. What personal data do we collect?
We collect personal data from you whenever you interact with our website or social media, including when you place an order purchases, when you browse our Websites or when you sign up to receive any of our communications such as email marketing. When providing personal data to us through a form, we indicate which personal data is optional. Please note that, when collection of personal data is required or necessary either as needed for us to fulfil your order or based on legal obligation and you elect not to provide the personal data, we may not be able to accept or fulfil your order.
The types of personal data that we will collect, store, maintain or process includes the following. We provide further details regarding the use of the personal data in Clause 8.
Personal data you provide when you place an order from us
Your contact details you provide when placing your order, including name, title, billing address, telephone numbers and e-mail address will enable us to maintain day-to-day contact through the fulfilment phase of your order
In order to progress your order through the mandatory compliance process we will also ask for additional business and personal information including…
- Company registered number, VAT number, company and card turnover, stock levels and ownership information relating to your own fulfilment process, date of birth of main contacts and persons with a significant interest in your business along with home and personal mobile numbers.
- Bank details in the form of a bank statement, we may also ask for other personal and business ID such as passport, driving licence and utility bills. All have to be dated within the last 3 months to be valid for the compliance process.
For this reason, we commit to destroying by secure shredding any and all paper or electronic documents that have been provided as part of the compliance process within three months of receipt.
Additional Personal Data obtained when you use our Websites
- Details of your online browsing activities on our Websites such as the pages visited and the parts of the Websites used
- Details of the type of device used to access our Websites, your device IP address, and your device location
Additional Personal Data obtained through contact with us
Details of your interaction with emails that we send you including links that you click and emails that you open
If contact occurs between us, we will keep a record of that correspondence, including your name and contact data, and details of your customer care issues or other concerns and our responses
Our Websites are not intended for use by persons under the age of 18 and our terms and conditions require that a person be 18 or older when placing an order with us. If you believe we have collected personal data from a person under the age of 18, please notify us at the information provided in Clause 14.
3. How we use the personal data we collect from you?
We will use your personal data for the following purposes:
To fulfil your order.
To process your order.
To provide data to one of three third party companies who may fulfil your order on our behalf. This will be restricted to some or all of the following…
- NetPay Merchant Services Ltd
- First Data Europe Ltd
- GPUK LLP T/A Global Payments
To provide order confirmation on any order placed with us
For customer care purposes
- To address any customer care issues that occur either with respect to a product or delivery, or a complaint or enquiry that you or your recipient raise with us
- To contact you with any changes, cancellation or other issues with your order
- To manage any registered accounts you have through the Websites
- To obtain customer feedback with respect to an order either from you or your recipient (to the extent permitted under the applicable law)
NOTE: Please note that you will receive communications with respect to fulfilling your order or for customer care purposes even if you opt out of receiving marketing communications.
For marketing purposes:
- To keep you up-to-date with new products and news that we think will be of interest to you
- To provide you with promotional offers
- To personalise your experience with Secure Payment Solutions and Carefree Consultancy Ltd by providing products and information tailored to you through your purchasing history with us
For marketing through third parties:
For internal business purposes:
We will use any of the personal data collected to help us to understand how many people visit our Websites, how well the Websites are working and to consider any improvements we may need to make to the Websites to improve your online experience. It also helps us determine what products and services you are interested in and what you or other customers might wish to purchase from us in future.
More specifically, we may use your personal data for the following internal business purposes:
- To analyse your browsing and purchasing activity on our Websites, including any search terms you may have entered into our Websites
- To analyse the demographic data we collect when you place your order or otherwise use our Websites including your title, address, IP address, browser type, and occasions for which you purchase in order to offer you better products and services and improve our business
- To analyse customers shopping with us to understand our target audience for the purposes of selecting similar customers for advertising purposes
- To analyse your responses to our marketing communications
- To ensure our online content is presented in the most effective manner for you and your electronic device(s) i.e. tailored for a desktop computer, tablet, iPhone or Android
- To obtain customer feedback with respect to an order either from you or your recipient (to the extent permitted under the applicable law) to determine the quality of the customer or recipient experience and to improve customer care experiences
- To develop and provide new or improved products or services
- For crime and fraud prevention, detection and related matters, including cooperation with the police and similar authorities with their lawful queries and investigations
- To confirm your identity, as necessary
- To comply with any legal obligation for the purposes of good governance or regulatory guidance with respect to applicable law
- With respect to any legal claims or related guidance by our advisors
- With respect to any mergers or acquisitions or other business or legal affairs as further described in Clause 9
4. When may you opt out of marketing communications?
You have the right to opt out of receiving direct marketing communications at any time. We will address your opt out request as soon as possible, but no longer than one month from the date we receive your request.
You may opt out of marketing communications or change your preferences with respect to marketing communications by:
Unsubscribing from emails using the unsubscribe link which can be found in all marketing emails
Contacting us via the contact information provided in this policy
6. How do we protect your personal data?
We are committed to protecting and respecting your privacy rights, and to ensuring that your personal data is safe and secure.
We use administrative, organisational, technical and physical safeguards to protect personal data. Our security controls are designed to protect your personal data from unauthorised alteration, access, disclosure, and use. We test our Websites, data centres, systems, and other assets for security vulnerabilities. In addition, at a minimum, our safeguards involve appropriate technical and organisational measures including, but not limited to, encryption services, review of our data collection, storage and processing practices (including physical security measures, to guard against unauthorised access to systems), scenario planning and crisis management protocols to ensure we are able to respond to cyber security attacks and data security incidents, regular penetration testing of systems, security controls to protect our IT infrastructure from external attack and unauthorised access, and internal policies setting out our data security approach and training for employees.
7. What can you do to protect your personal data?
We will never ask you to confirm any bank account or credit card details in writing or via email. If you receive an email or any other written communication claiming to be from us, asking you to provide this data, please ignore it and do not respond.
If you are using a computing device in a public location, especially if you are using the online billing and reporting tool supplied by NetPay Merchant Services Ltd known as Revolution, you should always log out and close the website browser when you have finished your online session.
If you create an account with us, you must keep your password private and avoid using the same password for multiple online accounts. Any password created should be at least 8 characters long and must include at least one upper case letter, one lower case letter and one symbol. We recommend regularly changing your password, which you can do within your account.
8. Our lawful basis for processing personal data
Carefree Consultancy Ltd relies on different lawful basis for processing personal data. In some cases, more than one lawful basis may apply with respect to the same personal data.
Contract: We collect and process personal data in order to fulfil the order you place with us, and in accordance with our contract with you to fulfil your order. Such personal data includes the items detailed in Clause 3 under the title “To fulfil your order”.
Legitimate Interest: We collect and process personal data for our legitimate interests in fulfilling and processing your order, any customer care issues, to conduct research, to send email marketing to you, handling legal claims, and for fraud identification and prevention checks. Such personal data includes the items detailed in Clause 3 under the title “For customer care purposes”, “For marketing purposes”, “For marketing through third parties” and “For internal business purposes”.
Legal Obligations: Carefree Consultancy Ltd is required to comply with applicable laws, rules and regulations as well as industry standards and orders by courts with jurisdiction over Carefree Consultancy Ltd. In doing so, we may collect and retain personal data. For example, Carefree Consultancy Ltd creates and maintains records of your orders to maintain the tax and accounting records required by applicable laws, and to share such records with the tax authorities as and when required.
9. When might we share your personal data with third parties?
We will share your personal data with certain third parties as previously named in order to fulfil and process your order, enable us to perform our contract to provide your purchase to you, provide our Websites and to provide you with marketing. The following is a list of types of third parties that may receive your personal data. Our third party providers are required to handle your personal data in accordance with appropriate data protection and security controls.
Website Improvement: In order to improve our online customer experience, Carefree Consultancy Ltd may contract with third parties who help us identify and make improvements to our website, provide website traffic data and website performance analysis information, and provide analysis on website performance focused on customer experience.
In addition to the reasons identified above, we may provide your personal data to third parties in the following circumstances:
Law Enforcement/Government Requests: We may be required by law to provide personal data to law enforcement, a government agency or in response to a search warrant, subpoena or other legally valid enquiry or order, or to an investigative body or civil litigant including emergency situations. We may also disclose personal data when we believe in good faith that disclosure is necessary to comply with relevant laws, for the establishment, exercise or defence of legal claims, to prevent and address fraud and other illegal activity, to prevent death or imminent bodily harm, or to protect or defend the rights, property or safety of our users, others and ourselves.
Carefree Consultancy Ltd Business and Legal Purposes/Mergers and Acquisitions: There may be business or legal reasons to disclose personal data. As an example, we may transfer data we have about you to third parties in connection with an actual or potential merger, consolidation, acquisition, reincorporation, sale/divestiture, acquisition or other similar transaction involving all or part of our company or any affiliate, or as part of a corporate reorganisation or stock sale or other change in corporate control. If we undergo such a business transition, personal data may be one of the assets that may be shared or transferred as part of the business transition and used by such third party as though such third party were Carefree Consultancy Ltd.
10. How long do we keep your personal data?
We will only retain your personal data for the purposes set out in this policy and for as long as we have a legal or business requirement to do so. Different retention periods apply for different types of personal data, however, the longest we will normally hold any personal data is 7 years after the last contact with such person or purchase by such person. The time period for retention will depend on applicable laws, rules or regulations that we are required to follow, whether there is an ongoing request or query or other type of legal claim or dispute, the type of information we are holding and whether we are asked by you or a regulatory authority to keep the personal data.
11. Your rights to access your data and rectify any inaccuracies in your personal data
We fully respect that your personal data is owned by you and that you have certain rights with respect to the personal data. Our goal is to respect your rights. Please understand that we may have certain obligations to maintain personal data records despite your requests to exercise the following rights, such as for legal and accounting purposes. We ask that you read these rights carefully.
Right of Access (also known as “Subject Access Request”): To receive a copy of the personal data we hold about you, please contact us, see the Contact Details section below. Please understand that you will need to provide a copy of two of the following separate pieces of identification:
- Driving licence
- Birth certificate
- Utility bill (covering the last 3/6 months)
- Current vehicle registration document
- Bank statement (covering the last 3/6 months)
- Rent book (covering the last 3/6 months)
- Right to Rectification: You may ask us to update and correct any out-of-date or incorrect personal data that we hold about you, or to complete incomplete personal data.
12. Your additional rights with respect to your personal data
You may have the following additional rights, detailed below:
Right to Erasure (also known as “the Right to be Forgotten”): For a limited list of reasons, you may request that your personal data is removed from our systems.
Right to Restrict: For a limited list of reasons, you may request that we cease using or that we suppress your personal data.
Right to Object: You may object to our use of your personal data.
Right to Data Portability: Where we use your personal data based on your consent or to enter or perform a contract with you, and our processing is carried out by automated means, you may request that any personal data you have provided to us be transmitted electronically to you or to another supplier (to the extent feasible).
Please note that if we erase all information about you and you make a future purchase or otherwise become a future customer, then we will not be aware of your prior requests or objections.
In respect of the additional rights outlined above, we request that you contact us via the Contact Details shown in Clause 14 below and we will provide you with additional information regarding your rights in connection with your specific request.
Right to Lodge a Complaint: You have the right to lodge a complaint with the supervisory authority. Carefree Consultancy Ltd’s supervisory authority is the Information Commissioner’s Office, see website www.ico.org.uk for details.
13. Contact details
We have a Data Protection Officer who informs and advises us about and to ensure that we remain compliant with data protection laws. The Data Protection Officer should be your first point of contact if you have any queries or concerns about personal data. Our Data Protection Officer can be contacted at:
Email: [email protected]
Data Protection Officer
Carefree Consultancy Ltd
15. Updates to this policy
We may in future use technology to track the patterns of behaviour of registered and non-registered visitors to our site. This can include using a “cookie” which is a small file stored on your browser. The information collected in this way can be used to identify you unless you modify your browser to prevent this happening – guidance for which is set out below. We also aggregate this data to perform statistical analyses of the characteristics and behaviour of visitors to our Websites. Cookies are also used as a further means of ensuring private and secure purchase sessions are operated within the Websites.
We may use third party advertising companies to serve advertisements on our behalf. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous. Your browser can be modified to not accept cookies – guidance for which is provided in the paragraph below.
You have the ability to accept or decline cookies by modifying the settings in your browser (for example, using Internet Explorer select ‘internet options’ from the ‘tools’ menu, then click ‘security’, followed by ‘custom level’ and select ‘disable cookies’). However, you may not be able to use all the interactive features of our Websites if cookies are disabled. For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org.