Privacy policies are also sometimes referred to as a ‘privacy notices’ or ‘fair processing notices’.
We are committed to protecting and respecting your privacy. This policy explains the types of personal data we collect, how we use that information, who we share it with, how we protect that information, and your legal rights in relation to your personal data.
This policy governs the collection and use of personal data by Warrant Group. This includes any personal data you may provide as part of any contract you enter into with us, any personal data you provide (or is available to us) through your use of our website and which we may obtain from other sources.
When we refer to personal data in this policy, this means any information about an individual from which that person can be identified. More detail about this is set out in section 6..
It is important that you read this policy together with any other privacy notice (or ‘fair processing’ notice) we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This policy supplements any such other notices and is not intended to override them.
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the Data Protection Officer using the contact details set out at the bottom of this policy.
For the purpose of applicable data protection laws, the controller of your personal data is Warrant Group Limited, whose registered office is at 157 Regent Road, Liverpool, Merseyside L5 9TF. For more information about Warrant Group please see: WEBSITE URL.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any time, by contacting the Data Protection Officer using the contact details set out at the bottom of this policy.
We reserve the right to amend this policy at our sole discretion, without prior notice to you. We will notify you of any such changes (including when they will take effect). Your continued use of our services or our websites following the posting of changes to these terms means that you consent to those changes (but this does not affect your rights set out in section 14.).
This policy covers all personal data collected and used by Warrant Group.
In this policy “personal data” means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly. This may include information such as your name, title, date of birth, gender, postal address, email address(es), telephone number(s) and computer IP address.
The different types of data we may collect are referred to below. We use these terms elsewhere in this policy to cover the type of personal data referred to:
We may collect personal data about you from different sources detailed below.
Information you give us:
Unless expressly stated below, you are not bound by any contractual or statutory obligation to provide personal data to us. However, if you choose to enter into a contract with us then we will need certain information for the purposes of entering into and performing that contract (which may include personal data) and we may not be able to conclude a contract with you without that information.
When you access and browse our website (including when you fill in forms on our website), when you correspond with us by phone or email or other electronic means and when you enter into a contract with us or order our services, you may give us information about yourself.
The information you give us may include your name, any applicable business name, postal address, email address, telephone number(s), details of your employment status, income and finances and/or other personal data referred to in this policy. This includes personal data you provide when you:
Information we receive and collect from other sources:
We may obtain certain information about you from third party service providers, from government organisations or publicly available sources.
The different kinds of personal data about you which we may collect and process from third parties are:
Other information and uses:
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Such 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 any such 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 policy.
We do not collect any sensitive personal information (which the law refers to as ‘Special Categories of Personal Data’). This means information such as 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), plus information about criminal convictions or offences.
We will only use your personal data when the law allows us to. Each basis on which we are lawfully permitted to process your personal data is known as the ‘legal basis’ for processing.
The purposes for which we may use your personal data and the types of legal basis that we will rely on to process your personal data are set out in the table below. Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data (as shown in the table). Where more than one is shown, please contact us if you would like details about the specific legal basis we are relying on to process your personal data.
To use data analytics to improve our website, services, marketing, customer relationships and experiences.
|Purpose/Activity||Type of data||Legal basis for processing|
|To register you as a new customer.||
|To undertake credit checks in respect of you or your business.||
|To administer and perform any services you have ordered.||
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||
|To make suggestions and recommendations to you about goods or services that may be of interest to you.||
|To comply with legal requirements (including where you exercise any of your rights referred to in this policy), to exercise our legal rights and to bring or defend legal claims.||
We will only use your personal data for the purposes shown above. If we need to use your personal data for a different purpose, we will update this policy and notify you of the change before starting any such new processing.
Please note that in some circumstances we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes shown:
We may also disclose your personal data to third parties:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Our third-party service providers (to the extent they are acting as our data processors) are contractually bound to use personal data only to perform the services that we have engaged them to provide and they are only permitted to process your personal data in accordance with our instructions.
Please note that some of the third parties we share your personal data which are based outside the United Kingdom (UK), so their processing of your personal data will involve a transfer of data outside the UK. Please see section 10. about data being processed outside of the UK.
Usually your personal data will be stored in the United Kingdom (UK). However, some of our external third-party service providers are based outside the UK, so your personal data may be transferred to a destination outside of the UK. This means it may also be stored and processed at a destination outside of the UK, including by staff operating outside the UK who work for one of our service providers.
Whenever we transfer your personal data to our service providers outside of the UK, we ensure a similar degree of protection is afforded to it as applies within the UK, by ensuring that certain minimum legal safeguards are met or implemented. We take all steps that are mandatory or reasonably necessary to ensure that your personal data is treated securely and in accordance with applicable data protection laws.
In some instances, we are required by law to disclose personal data to third parties which are based outside the UK (such as overseas government authorities or regulators). In those circumstances, the third parties will not be acting as our data processors and therefore we are not responsible for securing the protection mentioned above.
Please contact us if you want further information about the circumstances in which we transfer your personal data out of the UK or the safeguards we use.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of the periods for which we retain different aspects of your personal data are set out in our Data Retention Policy at www.warrant-group.com/retention-policy.
In some circumstances, you can ask us to delete your data. Please see section 14. regarding ‘Your Rights’ for further information.
We use administrative, technical, and physical measures to safeguard personal data against loss, theft and unauthorised uses, access or modifications. Our staff and our third-party service providers are under a duty to process your personal data only in accordance with our instructions and they are subject to a duty of confidentiality regarding your personal data.
Certain areas of our website may be password protected. Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share your password(s) with anyone.
We have put in place procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of any breach where we are legally required to do so.
You have the rights set out below with respect to the personal data that we hold about you. To exercise any of these rights, you should contact us by using the contact details set out at the bottom of this policy.
You will not normally have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity when you seek to exercise any of your 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 may also contact you to ask you for further information in relation to your request to help clarify the scope of your request.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Your right to access the personal data we hold about you
You have the right to ask us whether or not we process your personal data and to request information on the purposes of data processing as well as confirmation on whether we use your personal data for these purposes only.
In some circumstances, we may not be able to give you access to the personal data we hold about you (for example, we may not be able to give you access if it would unreasonably affect someone else’s privacy or if giving you access poses a serious threat to someone’s life, health or safety).
You also have the right to be informed of the third parties to which we transfer your personal data within the scope of this policy.
Your right to have your personal data corrected
You can contact us to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
Your right to erasure of your personal data
You can ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, after you make your request.
Your right to request restriction of the processing of your personal data
You may ask us to suspend the processing of your personal data:
We will inform you when you decide to lift any such restriction on processing.
Your right to object to us processing your personal data
You have the right to ask us to stop processing your personal data:
Where you no longer wish to be contacted for direct marketing purposes, you can easily unsubscribe from our marketing communications at any time by following the instructions included in those marketing communications.
If you have consented to receive offers or marketing communications directly from any third parties, please note that those third parties (not us) are responsible for taking account of your rights, including your right to opt-out of receiving offers or marketing communications from them.
Where we are relying on your consent to process your personal data, you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Your right to object to automated decision making
You have the right not to be subject to a decision which is based exclusively on automated processing and produces a legal effect or a similarly significant effect on you. In these circumstances, you are entitled to obtain human intervention, express your point of view and obtain an explanation of the decision and challenge it. However, this right does not apply if the automated decision is necessary for entering into or performance of a contract between you and us, is authorised by law or is based on your explicit consent.
Please note, however, that we do not undertake any such automated processing.
Your right to have your personal data transmitted to another organisation
Where we process personal data about you which:
you have the right to ask us to provide you with the personal data we hold about you in a structured, commonly used and machine-readable format or, where technically feasible, to transmit that data to another organisation.
You have the right to lodge a complaint to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk), if you believe that we have not complied with applicable data protection laws. You also have a right to claim damages if processing of your personal data violates applicable data protection law.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you have any questions about this policy, or if you wish to exercise your rights as referred to in this policy, please contact us by:
Lynsey Morrison, Data Protection Officer
Warrant Group Limited
157 Regent Road