Privacy Policy

Be Money Savvy Privacy Notice

This Privacy Notice is v2.1.1 and is valid from 00:01hrs on 3 April 2020. It replaces and supersedes all other Privacy Notices associated with Be Money Savvy.

We take your privacy very seriously. This Privacy Policy details what personal data we collect and how we shall use it.

Changes to this Privacy Notice.

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notice for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we shall contact you to inform you.

Our Name & Contact Details.

The Data Controller of your personal data is Be Money Savvy Limited. This means that Be Money Savvy decides how your personal data is processed and for what purposes. Our contact details are:

Be Money Savvy
4th Floor,
St Georges House,
Peter St,
Manchester,
M2 3NQ.

Data Protection Officer Contact Details.

In observance of the General Data Protection Regulation and the Data Protection Act 2018, Be Money Savvy have chosen to establish a Data Protection Officer. Should you wish to contact our Data Protection Officer regarding a data protection matter you can do so by emailing dpo@bemoneysavvy.co.uk, or writing to:

Data Protection Officer
Be Money Savvy
4th Floor,
St Georges House,
Peter St,
Manchester,
M2 3NQ.

Personal data categories we collect

We may collect, use, store and transfer different kinds of personal data about you which we have categorised as follows:

  • Identity Data: This includes first name, maiden name, last name, marital status, title, date of birth and gender.
  • Contact Data: This includes email address and telephone numbers.
  • Financial Data: This includes bank account information and payment details.
  • Compliance Data: This includes recorded calls for quality checks and staff training. Such recordings may also be used to help us combat fraud.
  • Technical Data: This includes internet protocol (IP) address, 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.
  • Usage Data: This includes information about how you use our website, products and services.
  • Marketing and Communications Data: This includes your preferences in receiving marketing from us and your communication preferences.
  • Aggregated Data: This includes 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.
  • Special Categories of Personal Data: This includes health and vulnerability related data that you may voluntarily share with us during the fulfilment of our services to you. We will always ask for your explicit consent to record and share Special Category Data.

For what purposes do we process personal data, and what are the lawful basis’ by which we process data?

Be Money Savvy processes your Personal Data for the following purposes:

For What Purposes Do We Process Personal Data?
“Be Money Savvy processes your data to…”

What is the lawful basis by which we process the data?

Supply, perform, manage and fulfil our products and services to you

Contract

Make and manage customer payments

Contract

Manage fees and charges due on customer payments

Contract

Communicate with clients to fulfil, administer or enforce contractual obligations via email, telephone, SMS text, postal mail and push notifications;

Contract

Communicate with customers where we have your consent to do so via email, telephone, SMS text, postal mail and push notifications;

Consent

Communicate with clients on matters where we have a legal obligation to do so via email, telephone, SMS text, postal mail and push notifications;

Legal Obligation

Communicate with clients on matters where we have a legitimate interest to do so (see legitimate interest section below), via email, telephone, SMS text, postal mail and push notifications;

Legitimate Interest

Direct market similar or aligned new products and services to our existing customers;

Legitimate Interest

Request specific consent to share customer personal data with specific fulfilment partners so that they may direct market similar or aligned new products and services to our existing customers;

Legitimate Interest

Verify the identity of individuals where necessary including for Subject Access Requests (SAR);

Contract

Update clients about changes to how we process their personal data and/or new processing activities via email, telephone, SMS text, postal mail;

Legal Obligation

Gather feedback for service and product improvement via email, telephone, SMS text, postal mail;

Legitimate Interest

Share testimonials, case studies and feedback on our website and future marketing;

Consent

Resolve complaints and/or disputes;

Legitimate Interest

Request continuation of Consent prior to consent expiry; 

Consent

Collect payments or arrears should we have the need to do so; 

Legitimate Interest

Protect our organisation, staff, associates, suppliers, partners and clients; 

Legitimate Interest

Prevent, detect and investigate fraud;

Legal Obligation

Prevent, detect and investigate crime; 

Legal Obligation

Comply with the law;

Legal obligation

Fulfil our statutory or regulatory obligations;

Legal obligation

Maintain our own accounts and records;

Legal obligation

For reporting, analytics and product/service improvement (including training);

Legitimate Interest

Improve and maintain data accuracy or completeness;

Legitimate Interest

Track your email engagement;

Legitimate Interest

Personalise your online experience;

Legitimate Interest

Conduct market research.

Legitimate Interest

Sell your personal data

Legitimate Interest

What are our legitimate interests for processing your data?

Where we have used legitimate interest as the lawful basis for processing your personal data, we may:

  • Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our current products and services and a soft opt-in exists;
  • Request specific consent to share customer personal data with specific fulfilment partners so that they may direct market similar or aligned new products and services to our existing customers;
  • For reporting, analytics and product/service improvement (including training);
  • Improve and maintain data accuracy or completeness;
  • Track your email engagement;
  • Personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors;
  • Conduct market research. Including research on the demographics, interests and behaviour of our customers in order to help us gain a better understanding of different audiences and enable us to improve our service. This research may be carried out internally by our employees or we may ask another company to do this work for us. Data will be anonymised to protect your data rights for research purposes.
  • Sell your personal data;
  • Resolve complaints and/or disputes;

Sharing your personal data

Be Money Savvy may choose to share your personal data internally and/or externally to the business. Where we choose to share your information, we shall do so for the following reasons:

  • Where we have your “Consent” to do so. Where we process your data under the consent lawful basis you have the right to withdraw consent. Please refer to “Your Right to Withdraw Consent” section below;
  • Where necessary to fulfil the services and/or products we are “Contracted” to provide to you;
  • Where we have a “Legal Obligation” and are required by law and to law enforcement agencies, judicial bodies, government entities, tax authorities or regulating bodies around the world, this includes communicating with you to update you about our privacy notice and changes to how we process your personal data;
  • Where we have “Legitimate Interest” to do so, including;
    • For the purposes listed in the “What are our legitimate interests for processing your data?” section above.
    • For reporting, analytics and service improvement purposes across our trading styles and/or within any future group construct should Be Money Savvy establish or become part of a group.
    • Where one of our registered trading styles and/or current associated businesses provides a product or service similar/aligned with our organisation’s aim to help clients maximise the potential of their data in a fair, lawful and transparent manner that we do not currently provide ourselves.  These companies include:
    • Red Star Financial Management Limited
    • Red Star Financial Services Limited
    • Rank Right Advertising Limited
    • JKZ 10 Limited
    • Sierra Kilo Limited
    • Evason Fildes Limited
    • Front Row Claims Limited
    • Purple & Ginger Limited
    • Perligo Limited
    • AIG
    • Aviva
    • Aegon
    • Aegeas
    • Axa
    • Churchill Sloan Limited
    • Digital Rewards Group Limited
    • Dragon Brokers Limited
    • HSBC
    • Legal & General
    • Midas Underwriting
    • Pride Planning
    • Vitality
    • Royal London
    • RSA – Royal Sun Alliance
    • Liverpool Victoria
    • One Family
    • Scottish Widows
    • Solution Builder
    • Uinsure
    • Underwrite Me
    • UK General Insurance Group
    • Where an external 3rd Party, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and which we reasonably believe would be of benefit to you and you would reasonably expect to receive and is similar/aligned to our organisation. In this case we would contact you using Legitimate Interest to request specific Consent to share your personal information.
    • Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites;
    • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
    • Where we outsource support functions of our organisations to trusted partners. The categories of these recipients include:

Categories

Who we use

Privacy Notice

Web analytics service providers

Google Analytics

https://policies.google.com/privacy?hl=en

Social Media Provider

LinkedIn

https://www.linkedin.com/legal/privacy-policy

Facebook

https://en-gb.facebook.com/privacy/explanation

Twitter

https://twitter.com/en/privacy

Instagram

https://help.instagram.com/519522125107875

Google Ads

https://policies.google.com/technologies/ads

Facebook Ads

https://en-gb.facebook.com/policy.php

Microsoft – Bing

https://privacy.microsoft.com/en-gb/privacystatement

Customer Relationship Management System

Aquarium

https://aqinsure.tech/privacy-policy/

Cookie Provider

Cookiebot

https://www.cookiebot.com/en/privacy-policy/

Data Accuracy Support Provider

UK Search

https://www.uksearchlimited.com/ksupload/userfiles/Privacy-Policy-and-Fair-Processing-Notice-V6-UKSL-070918.pdf

Debt collection support providers;

UK Search

https://www.uksearchlimited.com/ksupload/userfiles/Privacy-Policy-and-Fair-Processing-Notice-V6-UKSL-070918.pdf

IT support providers;

Pareto IT LLP

TBC

Call & SMS Communication Provider

24X

http://24x.com/GDPR/PrivacyPolicy.pdf

Email Delivery

Mail Chimp

https://mailchimp.com/legal/privacy/

Mail scanning & support providers

Managed Inc

https://managedink.co.uk/wp-content/uploads/2018/07/Privacy-Policy.pdf

Feedback/review service providers;

Reviews.io

https://www.reviews.io/front/business-user-privacy-policy

Compliance Consultants

CSS Assure

https://www.cssassure.com/privacy-notice

Where we choose and/or have your permission to share your personal data with 3rd Parties we will, where appropriate, ensure that they have signed a contract that requires them to:

  • Abide by the requirements of all relevant data protection and privacy legislation;
  • Treat your information as carefully as we would;
  • Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation); and
  • Allow us to carry out checks to ensure they are doing all these things.

Selling your personal data

Be Money Savvy may choose to sell your personal data.

You have the Right to Object to us selling your personal data at any time and can do so by informing us by telephone, post or email.

Where we choose to sell your information, we shall do so in the following circumstances:

  • Where we have your “Consent” to do so;
  • Where we have a “Legitimate Interest” to do so, including;
    • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
    • For the purposes of generating revenue for our business we may sell your data to the categories of industry listed below:

Financial Services

Home, Property & Related Industries

Other

Mortgages

Home / Purchase Survey Services

Tree Surgery

Charities

Life Insurance

Home Removal Companies

Log burner services – incl wood supplies and chimney sweep

Lifestyle

Home & Contents Insurance

General Building & Home Improvement / Renovation Services

Glazing, door, window and conservatory suppliers and services

Mail Order

Car Insurance

Blacksmith

Home Security Services – incl CCTV & Alarms

Marketing services

Legal Services – Conveyancing, Wills, Trusts etc

Bathroom Fitters

Renewable Energy Services

Entertainment, Gaming, Leisure

Mis-Sold Financial Products

Joiner & Carpentry Services

Home Maintenance Services – Window Cleaners / Bin Cleaners / Drive & Patio Cleaners

Public Sector

Banking

Drainage specialists

White Goods & Appliance Providers

Fast Moving Commercial Goods (FMCG)

Financial Products

Driveway Specialists

Kitchen Designer and Fitter Services

Publishing/Media

Claims Management

Septic tank & waste removers

Home Furnishings

Retail & lifestyle

Pre-paid Funeral Plans

Floor fitter

Garden Improvement, Management, Maintenance & Equipment

Gambling and Lotteries

Funeral Plan

Electrical Services – including safety inspections

Utilities Providers – Gas

Travel

Private Medical Insurance

Plumbing Services – including boilers

Mobile, Telecommunication & Home Entertainment Providers

Cosmetic Surgery

Breakdown Cover and Recovery Services

Gas & Heating Services

Schools & Education facilities

Health and Beauty

Travel Insurance

Handy man services

Childcare, creche and playgroups

Trace, Asset Repatriation and Debt Collection

Loft conversion services

Employment & Recruitment

Wine cellar services

Pets – Including kennelling, catteries, vet services, grooming services

Painting & Decoration Services

Fast Moving Consumer Goods – grocery shopping etc

Pest control services

Storage Providers

Plaster / renderer services

Cleaning companies

Roofer

Doctors & Dentists, Optometrists, Health Providers

Stonemason

Lock smiths

Swimming pool, swim spa and hot tub services – incl installation, maintenance

Do It Yourself businesses

Gardening landscaping and decking services

Gymnasiums

Tilers

Sports, recreation and social clubs

International Personal Data Transfer – Countries & Organisations.

Be Money Savvy may transfer personal data to countries outside of the UK and/or EEA.  If data is transferred outside of the EEA, Be Money Savvy will put in place Standard Contractual Clauses with the Data Controller or Data Processor which contractually obliges them to protect your information to the same standard required by the General Data Protection Regulation and Data Protection Act 2018 post 31 December 2020.

Personal Data Retention Period

Be Money Savvy has the following data retention policies:

  • Where a Regulating Body directs a statutory retention period, we shall retain the relevant data for the statutory period. For example, your financial transactions data shall be retained for 7 years;
  • Where you have purchased, or enquired about purchasing a Be Money Savvy product or services (including completion of one of our website’s product/service webforms), that is designed for you to claim money that you are eligible to claim; and/or will enable you to save money; and/or will strengthen your financial position, we shall retain any personal details applicable to the contract delivery for a period of 7 years after completion of the webform or the contract – whichever is later, or until you exercise your Right to Object or opt out.  During this time, we may contact you using legitimate interest to market additional products or services.
  • Where you have downloaded free content from our site, we shall retain your contact details (name, email, mobile telephone number) for a period of 5 years, or until you exercise your Right to Object or opt out.  During this time, we may contact you using legitimate interest to market similar free content that may be of interest to you.
  • Where you have signed up to receive information emails from Be Money Savvy, we shall retain your contact details (name, email, mobile telephone number, company, job title) for 5 years, or until you withdraw your consent.
  • When we no longer need this information, we will anonymise your data and/or dispose of it securely.

The rights available to individuals in respect of the processing

Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:

  • Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about your Right to Access here.  In most cases Be Money Savvy will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive (excessive means that you submit a subject access request multiple times for the same or similar information).  Fees will not exceed £50.  Information will be provided within 28 calendar days from the day you request it. We will take all reasonable steps to verify your identity before providing you with details of any personal information we may hold about you.
  • Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about your Right to Data Portability here.

If you wish to exercise any of your individual rights, you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing dpo@bemoneysavvy.co.uk.

Automated decision-making, including profiling.

Be Money Savvy does not use currently use automated decision-making tools or profiling in the processing of your personal data.

Your Right to Lodge a Complaint with the ICO

You have the right to lodge a complaint with the UK’s Supervising Authority: The Information Commissioners Office. Prior to lodging a complaint, Be Money Savvy would like the opportunity to address any complaint you may have.

Should you have a complaint please in the first instance contact our Data Protection Officer by emailing dpo@bemoneysavvy.co.uk or writing to:

Data Protection Officer
Be Money Savvy
4th Floor,
St Georges House,
Peter St,
Manchester,
M2 3NQ.

If your complaint has not been resolved, you can lodge a complaint with the Information Commissioners Office via email https://ico.org.uk/global/contact-us/email/ or by writing to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Or by telephone on 0303 123 1113.

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