Privacy Policy
Privacy and Cookie Policy for Creative Adviser Ltd
June 2019
1.Introduction
This Privacy and Cookie Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we collect from you (“you/your”) through the use of our services (“Services”), or the use of our website pensionadvice.org (“Website”), how that information may be used or disclosed by us and the safeguards we use to protect it.
Our Website and Services may contain links to third party websites that are not covered by this Privacy and Cookie Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.
We have drafted this Privacy and Cookie Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy and Cookie Policy. This Privacy and Cookie Policy may change from time to time and your continued use of the Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.
This Privacy and Cookie Policy was last updated in June 2019. Please check back regularly to keep informed of updates to this Privacy and Cookie Policy. Please read this Privacy and Cookie Policy carefully and ensure that you understand it. Your acceptance of our Privacy and Cookie Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy and Cookie Policy, you must stop using our Website immediately.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you have any comments on this Privacy and Cookie Policy, please email them to [email protected].
2. Who We Are
2.1 Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:
– Our Website address is pensionadvice.org
– Our company name is Creative Adviser Limited
– Our registered address is 35 King Street, Bristol BS1 4DZ
– Our nominated representative is Stephen Hill and they can be contacted at [email protected]
2.2 We respect your right to privacy and will only process personal information you in accordance with the Data Protection Legislation which for the purposes of this Privacy and Cookie Policy shall mean: (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 2018 and other applicable privacy laws.
3. What we may collect
3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
– Identity Data includes first name, last name, username or similar identifier. When you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone number.
– Contact Data includes billing address, invoicing address, email address and telephone numbers.
– Financial Data includes bank account and payment card details.
– Transaction Data includes details about payments and other details of our Services you have purchased from us.
– Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
– Profile Data includes your username and password, reservations made by you, your interests, preferences, feedback and survey responses.
– Usage Data includes information about how you use our Website and Services.
– Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
– Interaction Data includes any information that you might provide to any discussion forums on the Website.
– Cookies Data like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them and what kind.
– Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.
– Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy and Cookie Policy.
3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy and Cookie Policy.
3.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) You have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
3.6 If we receive personal information in the course of providing our Services to you from another data subject, we expect you to have complete responsibility for ensuring that the contents of this Privacy and Cookie Policy are brought to their attention and you have obtained their consent in the process.
3.7 In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history.
4. How we may collect and use your data
4.1 We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
a) present Website content;
b) use any of our Services;
c) create an account on our Website;
d) subscribe to our Services or publications;
e) request marketing to be sent to you;
f) enter a competition, promotion or survey; or
g) give us some feedback.
4.2 In addition to the above, we may use the information in the following ways:
a) To personalise your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested.
b) Present Website content effectively to you.
c) Provide information, and services that you request, or (with your consent) which we think may interest you.
d) Carry out our contracts with you.
e) Provide the relevant Services to you
f) Tell you our charges.
4.3 If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you.
4.4 If you are a new customer, you will only be contacted if you agree to it.
4.5 We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.
4.6 In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 5, you can let us know at any time by contacting us at [email protected], and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.
4.7 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
4.8 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a) Where we need to perform the contract we are about to enter into or have entered into with you.
b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
c) Where we need to comply with a legal or regulatory obligation
4.9 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at [email protected], and we will either delete your data from our systems or move your data to our “unsubscribe list”. However, you acknowledge this will limit our ability to provide the best possible services to you.
4.10 As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email and/or telephone with information, news and offers on our Services. We agree that we will not do anything that we have not agreed to under this Privacy and Cookie Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5. Cookies
5.1 All Cookies used by and on our website are used in accordance with current English and EU Cookie Law.
5.2 We use cookies to recognise you and your preferences, improve our site’s performance and collect analytical information for ourselves and our business partners. Without the knowledge gained we would not be able to provide the service we do.
5.3 ‘Session cookies’ allow us to track your actions during a single browsing session, but they do not remain on your device afterwards.
5.4 ‘Persistent cookies’ remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our site.
5.5 Session and persistent cookies can be either first or third party cookies. A first-party cookie is set by the website being visited; a third-party cookie is set by a different website. Both types of cookie may be used by us or
our business partners.
5.6 Third Party Cookies we use include:
| Cookie | Description | Duration | Type |
|---|---|---|---|
| fr | The cookie is set by Facebook to show relevant advertisements to the users and measure and improve the advertisements. The cookie also tracks the behaviour of the user across the web on sites that have Facebook pixel or Facebook social plugin. | 2 months | Advertising |
| _ga | This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assigns a randomly generated number to identify unique visitors. | 2 years | Analytics |
| _gat | This cookies is installed by Google Universal Analytics to throttle the request rate to limit the collection of data on high traffic sites. | 1 minute | Performance |
| _gid | This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form. | 1 day | Analytics |
| _fbp | This cookie is set by Facebook to deliver advertisements on Facebook or a digital platform powered by Facebook advertising after visiting this website. | 2 months | Advertising |
| __cfduid | The cookie is set by CloudFlare. The cookie is used to identify individual clients behind a shared IP address or apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information. | 11 months | Necessary |
| __livechat | This cookie is installed by LiveChat. The cookie is used to provide live chat functionality between you and a member of our team. | 2 years | Functionality |
5.7 All our cookies are categorised by the role they fulfil on our website:
a. Strictly Necessary: these are essential to enable you to move around our website and use features such as secure services. Without these cookies such services could not be provided;
b. Functionality: allow the website to remember your choices and to personalise certain features. These cookies may be anonymised and cannot track your browsing activity on other websites; and
c. Performance: collect information as to how users use the website. These cookies don’t collect information that identifies a visitor. The information collected is aggregated and used to improve our website.
d. Advertising: 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.
e. None of the cookies employed are classified as Behavioural Targeting.
If at any time you wish to disable our cookies, you may do so through the settings on your browser. However, if you choose to disable or delete our cookies that will prevent certain important areas and features of our service from functioning properly. (but if you do so you will not be able to use certain important features of our service). You can find additional information at AboutCookies.org.
Notwithstanding, the audit undertaken regarding our cookies, it is possible we may have missed one from our list above. If you happen to find one that is being set on our site, please let us know.
6. Where we store your data and security
6.1 We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and to receive our Services and deal with payment. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements. Your acceptance of this Privacy and Cookie Policy shall be your consent permitting us to store or transfer data outside the EEA if it is necessary for us to do so.
6.2 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see the European Commission: EU-US Privacy Shield.
6.3 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
6.4 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6.5 By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
6.6 Any payments made by you, will be encrypted.
6.7 We have implemented security measures such as a firewall to protect any data and maintain a high level of security.
6.8 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
6.9 If we give you a password upon registration on our Website, you must keep it confidential. Please don’t share it.
6.10 We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of seven years after our relationship have ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.
7. Disclosing your information
We are allowed to disclose your information in the following cases:
7.1 We are allowed to disclose your information in the following cases:
7.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer.
7.1.2 We can disclose it to other businesses in our group.
7.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
7.1.4 We can exchange information with others to protect against fraud or credit risks.
7.2 We may, in the future, contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. If we do, we will update this Privacy and Cookie Policy to include a list of third parties that have access to your data. Currently, we do not share your data with any third parties.
7.3 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
8.Your rights
8.1 Under the GDPR, you have the right to:
– request access to, deletion of or correction of, your personal data held by us at no cost to you;
– request that your personal data be transferred to another person (data portability);
– be informed of what data processing is taking place;
– restrict processing;
– to object to processing of your personal data; and
– complain to a supervisory authority.
8.2 You also have rights with respect to automated decision-making and profiling as set out in section 11 below.
8.3 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
8.4 To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy and Cookie Policy, please contact us at [email protected].
9. Links to other sites
9.1 Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
10. Changes
10.1 If we change our Privacy and Cookie Policy, we will post the changes on this page. If we decide to, we may also email you.
11. Automated Decision-Making and Profiling
11.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
11.2 The right described in section 11.1 does not apply in the following circumstances:
a) the decision is necessary for the entry into, or performance of, a contract between the you and us;
b) the decision is authorised by law; or
c) you have given you explicit consent.
11.3 Where we use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
12.Terms and Conditions
12.1 Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our Website.
13.Your Consent
13.1 By using our Website and by way of acknowledgment, you consent to our Privacy and Cookie Policy.
14. Dispute Resolution
14.1 The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy and Cookie Policy or any breach of it.
14.2 Any dispute shall not affect the parties’ ongoing obligations under this Privacy and Cookie Policy.
14.3 This Privacy and Cookie Policy, and any non-contractual rights arising hereunder, will be governed in accordance with English law, and the English courts shall have exclusive jurisdiction.