Welcome to the free4you Limited’s (referred to as free4you) privacy notice.
free4you respects your privacy and is committed to protecting your personal data.
This privacy notice will inform you as to how we look after your personal data
when you visit our website (regardless of where you visit it from) and tell you
about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to
the specific areas set out below. Alternatively you can download a pdf version
of the policy here.
Please also use the Glossary to understand the meaning of some of the terms used
in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how free4you collects and
processes your personal data through your use of this website, including any
data you may provide through this website when you sign up to receive
communications from us or subscribe for any of our products or
services.
This website is not intended for children and we do not knowingly collect data
relating to children.
It is important that you read this privacy notice 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 privacy notice supplements the other
notices and is not intended to override them.
Controller
free4you Limited is the data controller and responsible for your personal data
(collectively referred to as “free4you”, "we", "us" or "our" in this
privacy notice).
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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 6 June 2018 and historic versions can
be obtained by contacting us.
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.
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
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).
We may collect, use, store and transfer different kinds of personal data about
you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or
similar identifier, marital status, title, date of birth and gender.
- Contact Data includes home address, delivery address, email address and
telephone numbers.
- 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, products selected by you,
your interests, preferences, your feedback and survey responses.
- Usage Data includes information about how you use our website, products and
services.
- Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
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 notice.
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.
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 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 Data and Contact Data by
filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when 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 about your equipment, browsing
actions and patterns. We collect this personal data by using cookies, server
logs and other similar technologies. We may also 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 we need to perform the contract we are about to enter into or have
entered into with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on
to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal
data other than in relation to 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.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan
to use your personal data, and which of the legal bases we rely on to do so. We
have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please
contact us if you need details about the specific legal ground we are relying on
to process your personal data where more than one ground has been set out in the
table below.
| Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer |
(a) Identity
(b) Contact
|
Performance of a contract with you |
| To process and deliver your order |
(a) Identity
(b) Contact
(c) Marketing and Communications
|
Performance of a contract with you |
| To receive your feedback on products you have tried |
(a) Identity
(b) Contact
(c) Profile
(d) Usage
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to report your product
feedback on an anonymous basis to product manufacturers) Anonymised
information will also be available in the public domain
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated
and to study how customers use our products/services)
|
| To enable you to partake in a prize draw, competition or complete a
survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use
our products/services, to develop them and grow our business)
|
| To administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support,
reporting and hosting of data)
|
(a) Identity
(b) Contact
(c) Technical
|
(a) Necessary for our legitimate interests (for running our business,
provision of administration and IT services, network security, to
prevent fraud and in the context of a business reorganisation or group
restructuring exercise)
(b) Necessary to comply with a legal obligation
|
| To deliver relevant website content and advertisements to you and
measure or understand the effectiveness of the advertising we serve to
you
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
|
Necessary for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform
our marketing strategy)
|
| To use data analytics to improve our website, products/services,
marketing, customer relationships and experiences
|
(a) Technical
(b) Usage
|
Necessary for our legitimate interests (to define types of customers for
our products and services, to keep our website updated and relevant, to
develop our business and to inform our marketing strategy)
|
| To make suggestions and recommendations to you about goods or services
that may be of interest to you
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
|
Necessary for our legitimate interests (to develop our products/services
and grow our business)
|
Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. We have established the following
personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data 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 if you have requested
information from us or received goods or 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.
Third-party marketing
We will get your express opt-in consent before we share your personal data with
any company outside of the free4you (or its group of companies) for marketing
purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any
time by logging into the website and checking or unchecking relevant boxes to
adjust your marketing preferences or by following the opt-out links on any
marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a product/service purchase, warranty
registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly. For more information about the cookies we use, please see.
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. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact us.
If we 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 for the
purposes set out in the table in paragraph 4 above.
- External Third Parties as set out in the Glossary.
- 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 in the same way as set out in this
privacy notice.
We require all third parties to respect the security of your personal data and to
treat it in accordance with the law. We do not allow our third-party service
providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our
instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area
(EEA).
7. Data security
We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered
or disclosed. 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.
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.
8. Data retention
How long will you use my personal data for?
By law we have to keep basic information about our customers (including Contact,
Identity, Financial and Transaction Data) for six years after they cease being
customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure
below for further information.
In some circumstances we may anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in
relation to your personal data:
Request access to your personal data (commonly known as a "data subject access
request"). This enables you to receive a copy of the personal data we hold about
you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you
to have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or
remove 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 information unlawfully or where we are
required to erase your personal data to comply with local law. 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, at the time
of your request.
Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on this ground
as you feel it impacts on your fundamental rights and freedoms. You also have
the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and
freedoms.
Request restriction of processing of your personal data. This enables you to ask
us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy; (b) where our use of the
data is unlawful but you do not want us to erase it; (c) where you need us to
hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims; or (d) you have objected to our use of your
data but we need to verify whether we have overriding legitimate grounds to use
it.
Request the transfer of your personal data to you or to a third party. We will
provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing
carried out before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact
us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any
of the other 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.
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 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
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 or you
have made a number of requests. In this case, we will notify you and keep you
updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best service/product and the best and
most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process
your personal data for our legitimate interests. We do not use your personal
data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests
against any potential impact on you in respect of specific activities by
contacting us
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data
where it is necessary for compliance with a legal or regulatory obligation that
we are subject to.
THIRD PARTIES
External Third Parties
- Service providers acting as processors based in the UK who provide IT and
system administration services.
- Professional advisers acting as processors or joint controllers including
lawyers, bankers, auditors and insurers based in the UK who provide
consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as
processors or joint controllers based in the UK who require reporting of
processing activities in certain circumstances.
