This policy may be updated from time to time to keep up with legal and/or business developments, so you should check it each time you submit information to any of our services. The date of the most recent changes to each section of the policy will appear at the bottom of the relevant page.
We collect and use different information depending on the way(s) in which you interact with us.
Types of information we may collect about you
When you sign up to or use our website, we may collect personal information about you. Different services may require different types of information.
If you are aged 16 or under, you must get your parent/guardian’s permission before you provide us with your personal information. Unless you have this consent, you are not allowed to give us your information.
Here are some more specific details about the information we collect:
- Information you give to us: information that you provide by filling in a form on our website. This includes information provided at the time of buying a subscription of our services, this information will normally include information about yourself (such as your name or date of birth) and contact details (such as address, email address, telephone number etc);
- Information about your location: if you have enabled located services on your device, we may collect information about your actual location. You can disable location services at any time by updating your preferences on your device;
- Information about transactions: if you purchase a subscription, we will make a record of the details of that transaction, including what products/services you have bought, and details of the payment made; and
- Contact information: if you contact us, we may keep a record of that correspondence.
As well as collecting information directly, we may receive personal information about you from third parties where you have provided your permission to them to share your information, or they are otherwise legally permitted or required to disclose your personal information to us. We may also collect information gathered from publicly available sources and social media platforms.
We may also compile and share aggregated data, such as statistical or demographic data.This gathers together your personal information and that of others in an aggregated, anonymised way. It does not directly or indirectly reveal your identity.
If you fail to provide the personal information we have requested where we are required to collect this by law, or to perform our contract with you, we may be unable to perform the contract we have or are trying to enter into with you. However, we will notify you if this is the case.
How we look after your information
We are committed to protecting your personal information, and we have appropriate procedures and security features in place to keep it secure and prevent unauthorised access.
Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee its security and when giving us your information you do so at your own risk.
The information that we collect from you may be transferred to, stored at, or accessed from a destination outside the European Economic Area (which consists of the EU, Iceland, Norway and Lichtenstein) by us (or by someone acting on our behalf) where it is necessary to fulfil an order, process payment details or provide you with other services. Where this is the case, we will always ensure that appropriate protection is in place to protect your personal information.
How and why we use your information
We may use your information for a number of purposes, depending on how and where we receive it. We will always do so in one or more of the lawful ways set out here:
- We will set out why we would like to use your data and ask for your permission to do this. For example, we will do this wherewe would like to send you carefully selected newsletters, special offers and/or promotions of our website WHICH MUA by email or post
- Where our processing of your information is based on your consent, you can withdraw this consent at any time using the details on the “Contact” page of the website, by changing your account settings if you have an online account with us, or by changing your website browser or mobile device settings in relation to cookies.
- You will also be given a straightforward way to opt out of our marketing messages each time you receive a communication from us. Please note that it may take up to two weeks to implement changes to your preferences.
To perform our contract with you
In some circumstances, we will need to use your information to help us provide you with the product or service you have ordered. For example, we will do this:
- requests for services or information and to process payments and any other requests you make of us;
- if we need to contact you for reasons related to the service you have signed up for e.g. to provide you with password reminders, to inform you of new or improved benefits relating to the product or service, or to notify you that a particular service has been suspended for maintenance;
- to tell you about changes to our service.
Sometimes we will use your information for specific purposes we have carefully considered, taking into account any potential impact on you and your rights, where it will help us to enhance the services we provide and benefit our customers. This may include:
- to personalise or improve our communications with you.
- to contact you about a submission or contribution you have made to our website
- to invite you to participate in surveys about our service (participation is always voluntary), in order to help us improve these in future;
- to keep our records up to date, including any correspondence or communications between us;
- to administer and protect our business and websites (including troubleshooting, system maintenance, testing, reporting etc);
- to contact you by phone and/or post with details of special offers or promotions that we think may be of interest to you, where we have explained this when we collect your information and you have not opted-out of receiving such messages. We may also contact you about renewing your subscription when this has lapsed.
- to investigate and protect against fraudulent, unauthorised, or illegal activity
Where we process your information based on legitimate interest grounds, you may object to this at any time and we will stop using it for that purpose unless we have compelling legitimate grounds or other legal reason for continuing to use it.
We are entitled to process your personal information where we are under a legal or regulatory obligation to do so.
Who we share your information with
We will only use your information within Which MUA to provide you with the service or product you have requested, or to provide you with information about other Which MUA products or services where we have your permission or a legitimate interest in doing so.
We will also disclose your information to other trusted third parties with your consent, or where we have justification for doing so. This may include:
- with a third party who is helping us to provide a service to you, such as payment
- processors, customer management and assistance, or our IT and database services;
- with a third party who is helping us develop and improve our services to you, such as analytics providers;
- with a third party who is helping us select and deliver interesting and relevant advertising to you and/or other potential customers, such as advertising networks, social media platforms, and search engines. We may also occasionally share anonymous data segments with advertisers to help them make their advertising outside our sites more relevant;
- with our trusted business partners to provide insight and analysis of our customers, or where you have told us you would like to receive offers/promotions from those partners;
- when the disclosure is required or permitted by law (e.g. to government bodies and law enforcement agencies).
Where we pass personal information to a third party acting on our behalf, in addition to the measures set out above we also require them to treat this information with at least the same protection we do. We only permit them to process your personal data for specified purposes, and in accordance with our instructions. We do not share more information with them than is necessary for the relevant purpose.
How long we hold information for
We collect all personal information for one or more specific purpose. This means that we hold your information on our systems for as long as is necessary to fulfil the purpose, or as long as is set out in any relevant contract you hold with us. Once that purpose has been fulfilled, we will securely delete the data, unless we are required to keep the data longer for legal, tax or accounting reasons. For example, if you change your registration profile to opt-out of receiving communications from us, your relevant details will stay on the system so we can ensure that we do not contact you in the future.
Alternatively, we will anonymise your information, so that we (or anyone else) can no longer tell that the data relates to you, at which point your information will cease to be considered personal information.
Your rights and further information
You have the following rights in relation to the personal data we hold about you:
- access:you can ask us for a copy of any personal information that we hold about you. If you require additional copies of the data, we may charge an administrative fee;
- corrections:we use reasonable efforts to update the personal information we hold about you, but you can request that we amend any inaccurate or incomplete personal data that we hold;
- restriction:you can request that we suspend the processing of your personal data where, for example, you object to our processing of it (see below) or while we correct any inaccuracies;
- objection:you can tell us that you object to the processing of your personal data where, for example, we are using it for direct marketing purposes, or we are processing it on the grounds of “legitimate interests” (see above) and you feel it impacts your rights. If we feel we have a compelling reason to carry on this processing we will let you know, otherwise we will no longer use it for that purpose;
- withdrawal of consent:where you have given us your consent to process your personal data for a particular purpose (or purposes), you can withdraw this permission at any time by letting us know;
- deletion:we use reasonable efforts to delete your data when we no longer need it. However, you can also ask us to delete your personal data from our records in certain circumstances – for example, where you have withdrawn your consent for us to use it. If we are unable to comply with your request for legal reasons, we will tell you this; and
- transfer:you can ask for any personal data you have previously provided to us to be transferred to you in a usable electronic format, or to a third party (where this is technically feasible), so you can use it elsewhere.
When you make a request, we may request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We try to respond to all legitimate requests within one month, unless your request is particularly complex or you have made a number of requests, in which case it may take longer. If this is the case, we will keep you updated.
How to contact us
- Tel: +44(0)800 206 2677
- Email: firstname.lastname@example.org
It would be very helpful for us if you could include your full name, username (if applicable), your postcode, details of the service you are using and your subscription information when contacting us.
If you are unhappy with the way we have handled your personal data, or how we have responded to any request, please let us know using the contact details set out above. However, if we are unable to resolve the matter to your satisfaction you can also contact the Information Commissioner’s Office (www.ico.org.uk).
Last updated: DECEMBER 2019