SummaryThis Privacy Notice describes how we collect, use, share, store or otherwise process the information we hold about you. Your personal information allows us to provide the products and services you have asked for, as well as enabling us to improve those products and services by understanding your interests and preferences.
Who we areWe are Causeway Connect Limited (‘Causeway Connect”) in the United Kingdom. Depending upon your relationship with us, we are the Data Controller or the Data Processor when you provide information to us or to our affiliates.
Legal basis for using your informationAll organisations need a legal reason to use your personal information, if they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. It’s quite complicated but below are the most relevant grounds you should be aware of.
With your consent (C)There are some activities where we process personal information with your consent, which you are able to withdraw at any time, although if you do, we may not be able to provide the product or service you have requested. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. We will indicate in the Notice where we rely on consent.
To fulfil a contract (A)We also process your personal information in order to fulfil a contract we have with you. For example, when you order products and services from us, we will process your information to administer that transaction.
For a legitimate interest (LI)Sometimes we may use your information to help achieve our business objectives but only where that activity doesn’t negatively affect your rights. For example, we might use your information to communicate with you on the basis of our legitimate interest.
To comply with legal obligations (LO)There may be situations where we need to use your information to comply with legal obligations. For example, we are required by law to keep records of who is in our business premises in case there is an emergency, so we can make sure you’re safe.
What information do we collect?When you interact with our organisation, our products, and our services, we collect information about you and our interaction. Generally, this may include:
Your personal details;
Contact information, and preferences;
More sensitive information, for example when you tell us about dietary requirements, or disabilities, such as when you attend a seminar;
Information about your use of our products or services;
Images of you in areas of our organisation covered by CCTV;
Conversations you have when you call our sales or customer support teams;
Information about the devices you use to interact with us.
Where you provide information to us about other people, you need to make sure you have their permission to do so.
When and how we collect your informationWe may collect information you provide to us directly and indirectly when interacting with our products and services. This may include such interactions as:
Make an initial approach to use by email or on the phone;
Create, use or manage an online account;
Visit our website or use our apps;
Fill out our online forms or registration cards;
Access our internet facilities;
Use social media login functionality;
Interact with us in online forums, by email, text, or on social media;
Our processorsThere may be situations where we use data processors – companies who act on our behalf – to collect your information for us. These processors can only use your information in accordance with our instructions and for the purposes stated in this Notice published on our websites and partner websites.
We also receive information about you indirectly when you interact with us. For example, when you visit our websites or use our apps the devices you use may provide us with your general location (such as which country or region you’re in), or your IP address. We may also receive information from cookies and other technologies that are on your device or browser.
Our partners and Third PartiesWe collect information about you when it is provided to us by third parties. This might include when you interact anyone who promotes our products, brands, or services. You should always read the privacy policies of other third parties you use, as they will use your information in accordance with their own privacy policies.
We may also obtain information about you from our partners and other companies that have your permission to share your information both online and offline, like insight providers.
How we use your personal informationThe reason we use your information will often be obvious from the way you interact with us.
The legal basis for processing is listed, and where there is more than one, the exact grounds will depend on the activity. See the section above for an explanation of each.
Use of personal information BasisProvide you with the products and services you have requested, including responding to any enquiries, complaints or requests, and to manage our relationship. C, LI, A
Make decisions about what direct marketing to show you based on how you have interacted with us, and to improve our products and services online and offline, including our websites and apps LI
Monitor the use of our products and services and content, and also to comply with our legal obligations LI, LO
Provide linked services, like joint promotions with partners C, A, LI
Send you product or service related communications, service messages LO, LI, C, A
Send you direct marketing, where you have consented C, LI
To keep you safe and ensure your security LO, LI
Facilitate the restructuring or sale of all or part of our business LO, LI, C, A
Provide you with help and support where it may be required LI, A
Further Information on how we use your information
We sometimes use your information for other reasons, so to help we have added more information to these below.
Profiling and preferencesWe sometimes make decisions about you based on the way that you interact with us and the information we hold about you, this is called profiling. For example, understanding your business can help us guide you to the most relevant products.
Do not track signals or browser/device settingsOur websites are not designed to respond to “do not track” signals or browser/device settings.
Direct marketingIn addition to sending you information about the products and services you use, and where we have your permission, we may send you direct marketing communications about our products, services, events and offers, as well as those of our commercial partners that we think you’ll be interested in.
Direct marketing communications may be sent by post, email, telephone, SMS and MMS, and via other electronic means such as when you visit our websites or use our apps. This may also include any websites and apps of our partners who are in our advertising networks.
We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our products or services.
You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings.
Product related communications and “in-life” updates
We may use your information to send you newsletters, bulletins, and other triggered communications. For example, we may send you email or text messages about the product or service we have provided. You’ll be able to opt-out of these.
Service communications will be sent to you regarding products and services you interact with. These are important messages relating to the products and services we provide to you.
Payments and credit checksYour information may be used to take payment for products and services and may be used to verify credit details related to payments.
Disclosures required by law
Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
Data TransfersWhen you complete our registration forms or use our services, we may transfer your information to our processors – companies that carry out activities on our behalf, and only on our instructions.
Training and qualityIf you call contact us by phone or on chat the conversation may be recorded and listened to for training and quality purposes.
Social media loginOur websites and apps provide plug-ins to social media websites, including Facebook, Twitter, Google, Yahoo and LinkedIn.
If you make use of, or log-in to, the social media features on our websites or apps, we may (depending on your privacy settings) access, use and store information about you, including, but not limited to: your name, e-mail address, gender, location, profile, picture, contacts, and any other information you have chosen to make available.
How we share your personal informationWhere you provide your information to us we do not share it with any third parties except in the performance of a contract or in anticipation of a contract. Your information will only be shared and used in accordance with this notice, and where an agreement is in place to ensure that your information is protected. We won’t sell your personal information without your consent.
For example, we will share your information with a finance company for the administrative purposes of providing you or your organisation credit facilities, as well as making sure information is accurate, up to date and to enable business planning and continuity.
Sharing with our processorsThere may be situations where we use data processors – companies who act on our behalf – to process your information for us. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.
Sale of our businessIf we restructure or sell all or part of our business or business operations, we may transfer your information as part of that activity. Where this is the case your information will be used in accordance with this Notice unless you are notified otherwise.
Access and ControlControlling Communications
You can change your preferences about receiving direct marketing by opting-out of any marketing or product communication by emailing us using the contact details below. You can control the communications you receive from us, such as product or service related communications by following the instructions in any relevant communication.
Requesting copies of your informationYou may request a copy of your personal information which we may hold about you. You may also ask us to correct any inaccuracies in your personal information. This right may be restricted by law where disclosing information may result in the personal information of other individuals being disclosed and it would be unreasonable to do so.
Withdrawing consentWhere we may rely on consent to use your information, you have the right to withdraw that consent for that processing activity at any time. However, we may have the right to rely on an alternative legal basis for the processing activity and will inform you of that.
If you do withdraw consent we may not be able to provide you with the product or service you have requested.
Requesting copies of data transfer safeguardsIf you would like a copy of the applicable data transfer safeguards used when your information is transferred by us outside the EEA to non-adequate countries, please contact us.
Other rightsYou may have the right to object, erase, or restrict our processing of your information – for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.
Complaining to the regulatorIf you have any comments, concerns or complaints about our uses of your information we would ask that you contact us first, so that we can try and resolve any matter.
However, where we are unable to help, you are able to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence, who will be able to liaise with the UK Information Commissioner in the UK.
Retention of your informationWe shall retain your information in accordance with our records retention policy, or for as long as necessary for the uses set out in this notice or while there is a legitimate business reason for doing so.
If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.
Where you ask for your account to be closed, we will do this as soon as possible subject to any terms and conditions relating to the account. Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.
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Google AnalyticsWe also use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate visitors’ use of our site.
For more information on Google Analytics please go to this link.