Introduction

Welcome the FindRate Ltd privacy notice.

We respect your privacy. Therefore we committed to protecting your personal data on FindRate. This is privacy notice. It will inform you how we look after your personal data. Similarly it tells you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information about how we collect and process your data on FindRate. To sum up may include any data you may provide through this website. It may be when you sign up to our newsletter, purchase a product or service or take part in a competition. Children cannot use the FindRate website.

It is important that you read this privacy notice. Along with any other privacy notice or fair processing notice we may provide. It may be on specific occasions when we are collecting or processing personal data about you. So that you are aware of how and why we are using your data on FindRate. This privacy notice supplements the other notices and is not intended to override them.

Controller

You may have any questions about this privacy notice. It can include any requests to exercise your legal rights. Please email the FindRate Ltd Data Protection Officer at info@findrate.io.

You have the right to make a complaint. It can be at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authorities. So please contact us at FindRate in the first instance.

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you on FindRate is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you. All have been grouped as follows:

• Identity Data. It includes basic information like first name, maiden name, last name or username. It may include similar identifier. Such as marital status, title, date of birth and gender
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Marketing and Communications Data. It includes your preferences in receiving marketing from us and our third parties. And looks after your communication preferences.
• Financial Data includes bank account and payment card details.
• Technical Data. It includes internet protocol (IP) address, your login data, browser type and version. As well as time zone setting and location, browser plug-in types and versions, operating system and platform. And other technology on the devices you used to interact with or access this website.
• Personal data or personal information. It means any information which can identify a Profile Data. And includes your membership identification number, purchases or orders made by you. Includes your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
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We collect, use and share aggregated data. Such as statistical or demographic data for any purpose. Aggregated Data is data derived from your personal data. But we do not consider it as personal data in law as this data. It does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data. Use it to calculate the percentage of users accessing a specific website feature. But, we can combine or connect Aggregated Data with your personal data. It can directly or indirectly identify you. We treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you. And if you fail to provide that data when requested, we may not be able to perform the contract we have. Or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us. But we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms. Or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you place a request for services with FindRate Ltd. And includes circumstances in which you:

• • • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data. It includes about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. And may include that we receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

4. HOW WE USE YOUR PERSONAL DATA

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 where:
if need to perform the contract we are about to enter into or have entered into with you
it is necessary for our legitimate interests (or those of a third party). And your interests and fundamental rights do not override those interests.
we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data. We send 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.

Marketing

We strive to provide you with choices regarding certain personal data uses. It could be particularly around marketing and advertising:

Promotional offers from us

We use your Identity, Contact, Technical, Usage and Profile Data. It is to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us. As long as you have requested information from us. Or placed a request with us or purchased goods. In addition includes services from us or if you provided us with your details when you entered a competition. Or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages. It can be at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data. Personal data includes data provided to us as a result of a product/service purchase. Or product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it. Unless we reasonably consider that we need to use it for another reason. And that reason is compatible with the original purpose. You may wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose. Please contact us in regards to that.

There may be some cases where we would need to use your personal data for an unrelated purpose. We will notify you and we will explain the legal basis which allows us to do so.

Please note that 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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below. It may be for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary.
• Specific third parties such as Ducorp Ltd partners.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data. But in the same way as set out in this privacy notice.

6. NOTICE TO EUROPEAN ECONOMIC AREA (EEA) USERS

Some instances will involve transferring your data outside the EEA.

Many of our external third parties are based outside the EEA. So their processing of your personal data will involve a transfer of data outside the EEA.

We may need to transfer your personal data out of the EEA. First of all we will ensure a similar degree of protection is afforded to it. We ensure at least one of the following safeguards is implemented if we:

• will only transfer your personal data to specific countries. Countries that have been deemed to provide an adequate level of protection for personal data. Protection as per the European Commission.
• use certain service providers. We may use specific contracts approved by the European Commission. Contracts which give personal data the same protection it has in Europe.
• 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 European Commission: EU-US Privacy Shield.

Please contact us if you want further information. It could be on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures. This is to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. It also prevents that your data is altered or disclosed. In addition, we limit access to your personal data. It would be limited 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.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may request:

• access to your personal data.
• correction of your personal data.
• erasure of your personal data.
• object to processing of your personal data.
• restriction of processing your personal data.
• transfer of your personal data.
• to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

What we may need from you

We may need to 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. It is 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 on FindRate. This is to speed up our response.

Time limit to respond

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. Similarly if you have made a number of requests. In this case, we will notify you and keep you updated.

9. GLOSSARY

Third Parties

External Third Parties

• Partners can act as joint controllers or processors with FindRate. They may provide services pursuant to the contract we are about to enter into. Or have entered into with you.
• Service providers acting as processors based who provide IT and system administration services.
• Professional advisers can act as processors. Or joint controllers including lawyers, bankers, auditors and insurers. They can provide consultancy, banking, legal, insurance and accounting services