LAST UPDATED: 15TH NOVEMBER 2019
Protecting your personal details on our website.
Kwaleo Ltd (registered number No 09058164) is the controller for the purposes of the General Data Protection Regulation (the “GDPR”). Kwaleo Ltd company is registered in England & Wales and our registered office is at 133 Towerhouse 81 Fieldgate Street, London, England, E1 1GW.
The Website is brought to you by Kwaelo Ltd (also trading as kwaelo.com). We believe it is important to protect your Personal Data (as defined in the Data Protection Act 1998) and we are committed to giving you a personalised service that meets your needs in a way that also protects your privacy. This policy explains how we may collect Personal Data about you. It also explains some of the security measures we take to protect your Personal Data, and tells you certain things we will do and not do. You should read this policy in conjunction with the Website Terms.
When we first obtain Personal Data from you, or when you take a new service or product from us, we will give you the opportunity to tell us if you do or do not want to receive information from us about other services or products (as applicable). You can normally do this by ticking a box on an application form or contract. You may change your mind at any time by emailing us at the address below.
Some of the Personal Data we hold about you may be 'sensitive personal data' within the meaning of the Data Protection Act 1998, for example, information about your health or ethnic origin.
1. Collecting Information
We may collect Personal Data about you from a number of sources, including the following:
1.1. From you when you agree to take a service or product from us, in which case this may include your contact details, date of birth, how you will pay for the product or service and your bank details.
1.2. From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services.
1.3. From documents that are available to the public, such as the electoral register.
1.4. From third parties to whom you have provided information with your consent to pass it on to other organisations or persons.
2. Using Your Personal Information
2.1. Personal Data about our customers is an important part of our business and we shall only use your Personal Data for the following purposes and shall not keep such Personal Data longer than is necessary to fulfil these purposes:
2.1.1. To help us to identify you when you contact us.
2.1.2. To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the Personal Data you have provided and/or any information we hold about you and Personal Data from third party agencies (including credit reference agencies).
2.1.3. To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future.
2.1.4. To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information.
2.1.5. To help to prevent and detect fraud or loss.
2.1.6. To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us where
188.8.131.52. these products are similar to those you have already purchased from us,
184.108.40.206. you were given the opportunity to opt out of being contacted by us at the time your Personal Information was originally collected by us and at the time of our subsequent communications with you, and
220.127.116.11. you have not opted out of us contacting you.
2.1.7. To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners where you have expressly consented to us doing so.
2.1.8. To keep you up to date with our member benefit scheme under which, as part of your membership benefits, we will give you membership information and details of any special discounts and promotional offers we make from time to time to our members. If you do not wish to receive this benefit and promotional offers, please write to our Data Protection Manager at the address given in clause 7.1 below.
2.1.9. We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.
2.1.10. We may check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we will record this.
2.3. We may allow other people and organisations to use Personal Data we hold about you in the following circumstances:
2.3.1. If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case Personal Data held by us, about our customers, will be one of the transferred assets.
2.3.2. If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.
2.5. In connection with any transaction which we enter into with you:
2.5.1. We may from time to time need to carry out with one or more licensed credit reference and fraud prevention agencies:
18.104.22.168. credit checks where you have given us your express consent, and
22.214.171.124. fraud prevention checks.
We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.
2.5.2. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.
2.5.3. If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Manager at Kwaleo Ltd, 11, West London Studios, 402 Fulham Road, London, SW6 1HR.
3. Protecting Information
We have strict security measures to protect Personal Data.
3.1. We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
3.2. We reveal only the last five digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
3.3. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
3.4. It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
4. The internet
4.1. If you communicate with us using the internet, we may occasionally email you about our services and products. When you first give us Personal Data through the Website, we will normally give you the opportunity to say whether you would prefer us not to contact you by email. You can also always send us an email (at the address set out below) at any time if you change your mind.
4.2. Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered - this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.
- When we provide services, we want to make them easy, useful and reliable. This sometimes involves placing small amounts of information on your computer. These are called 'cookies'.
- These cookies cannot be used to identify you personally and are used to improve services for you, for example through:
- Letting you navigate between pages efficiently
- Enabling a service to recognise your computer so you don't have to give the same information during one task
- Recognising that you have already given a username and password so you don't need to enter it for every web page requested
- Measuring how many people are using services, so they can be made easier to use and that there is enough capacity to ensure they are fast.
To learn more about cookies, see:
Users typically have the opportunity to set their browser to accept all or some cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these options, of course, means that personalised services cannot be provided and the user may not be able to take full advantage of all of a website's features. Refer to your browser's Help section for specific guidance on how it allows you to manage cookies and how you may delete cookies you wish to remove from your computer.
Multiple cookies may be found in a single file depending on which browser you use.
The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide, as follows:
Category 1: strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
Category 2: performance cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
Category 3: functionality cookies
These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as a live chat session. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Category 4: targeting cookies or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
The list below shows the cookies that we use, other than those that are strictly necessary to this service. If you have any queries about these, or would like more information, please contact our Data Protection Manager at Kwaleo Ltd,133 Towerhouse 81 Fieldgate Street, London, England, E1 1GW. , or email us at firstname.lastname@example.org.
By using this website, you agree that we can place these types of cookies on your device.
6.1. The Website may include third-party advertising and links to other websites. We do not provide any personally identifiable customer Personal Data to these advertisers or third-party websites.
6.3. We exclude all liability for loss that you may incur when using these third party websites.
7. Further Information
7.4. If you would like access to the Personal Data that we hold about you, you can do this by emailing us at email@example.com or writing to us at the address noted above. There may be a nominal charge of £10 to cover administrative costs (This applies to UK customers only).
7.5. We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly. Please email us at firstname.lastname@example.org or write to us at the address above to update your Personal Data.