Version 1.0 — Last updated 16/07/2019
1.3. Our services comprise our information, call-connection and signposting services that we deliver by means of our websites and our premium rate numbers, and our SMS service (collectively ‘our services’). Our SMS service is where, at the end of your call to one of our premium rate numbers, we send you an SMS text message with the name and direct telephone number of the organisation you were looking for. By using our services, you acknowledge and agree that we may send you an SMS text message in this way. We will not send you a text message in any other circumstances.
2. IMPORTANT INFORMATION AND WHO WE ARE
2.1. This website and our services are not intended for children and we do not knowingly collect data relating to children.
2.5. 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.
2.7. 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.
3. THE DATA WE COLLECT ABOUT YOU
3.1. 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).
3.2. 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, last name, phone number, title, date of birth and gender.
• Contact Data includes postal address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you (including refunds) and other details of services you have purchased from us.
• 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 or use our services.
• Usage Data includes information about how you use our website and services, the third party listed organisations you were looking for and those you contacted.
3.4. We do not collect any Special Categories of Personal Data about you.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
4.1. 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:
• Use our services;
• Contact us about queries concerning our services;
• Give us feedback about our services;
• Make a complaint.
• Third parties or publicly available sources. We may receive personal data about you from a regulator if you register with them a complaint about us, as well as the following Technical Data from the following parties:
a) analytics providers, such as Google based, outside the EU; and
b) search information providers, such as Google and Bing, based outside the EU.
5. HOW WE USE YOUR PERSONAL DATA
5.1. 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 it to provide our services to you or deal with your query, feedback or complaint you send to us.
• 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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
5.2. We have set out in the table below, 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.
5.3. 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.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To provide our services to you||(a) Identity
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to operate out business effectively)
|To deal with any of your queries, feedback or complaints (including the refund of call charges)||(a) Identity
(e) Financial (if relevant)
(f) Transaction (if relevant)
|(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 services)
|To comply with our legal and regulatory obligations (including our associated liaison with a relevant regulator)||(a) Identity
|(a) Necessary to comply with a legal obligation|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(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 use data analytics to improve our websites and services||(a) Technical
|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)|
5.4. See paragraph 6 for the cookies we use.
CHANGE OF PURPOSE
5.5. 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.
5.6. 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.
5.7. 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.
6.2. Cookies are small text files that are placed automatically on your computer or mobile device when you browse the web.
• How many people have visited our website;
• What type of device they are using (which allows us to make sure visitors to our websites enjoy an excellent experience regardless of the device type);
• How long they spend on the website, what pages they look at and so on.
6.4. We use this information to continuously improve our website and refine our services. These web analytics services also let us know how visitors arrive at our website (for instance, either from a search engine site or a direct link) and whether they have been here before.
THE COOKIES WE USE
6.6. This allows us to understand where our visitors have come from, how they arrived and pages which interested them while they were visiting. By collecting that information, we can determine what content is popular and how are visitors like to use our website. This allows us to make continual improvements to our website resulting in a better user experience.
6.7. Google Analytics requires use of the following cookies:
|Cookie Name||Cookie type||What it does||Duration|
|__utma cookie||Persistent||It tracks visitors and records first visit (unique visit) and last visit (returning visit)||Until it expires or the cookie cache is cleared|
|__utmb cookie & __utmc cookie||Session||These cookies operate together to calculate website visit length||It expires at the end of the session (i.e. when the visitor leaves the page)|
|__utmz cookie||Semi-persistent||Monitors the HTTP referrer and notes where a visitor arrived from. It helps record keywords used to find the site, plus a visitor’s geolocation data||Six months after being set|
|__utmv Cookie||Persistent||Enables us to track visitor behaviour and measure site performance||Until the cookie cache is cleared|
6.8. If the configuration of your web browser that you are using to view this website is set to accept cookies, we take this and your continued use of our website as confirmation that you are happy for cookies to be used by CCL in the way described in paragraphs 6.5 to 6.7. Details are provided below about how to stop or prevent your browser from accepting cookies from the our websites. However, this may cause our website to stop working in the way you would expect.
6.9. You can usually disable cookies by adjusting your web browser settings to stop it from accepting cookies. However, this will likely limit the functionality of our website (and most of the others you visit using that web browser).
6.10. The method for disabling cookies and adjusting the cookie settings will depend on which web browser you are using.
6.11. Instructions for doing this in the most common web browsers can be found below:
6.12. For more information, you may wish to visit www.allaboutcookies.org which contains comprehensive information on how on how to manage cookies using a wide variety of web browsers.
7. DISCLOSURES OF YOUR PERSONAL DATA
7.1. We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
• Internal Third Parties (as set out in the Glossary).
• External Third Parties a(s set out in the Glossary).
7.2. 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.
8. INTERNATIONAL TRANSFERS
8.1. Some of our external third parties are based outside the European Economic Area (‘EEA’) so their processing of your personal data will involve a transfer of data outside the EEA.
8.2. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, or we may transfer your data to them in other circumstances where it is necessary for us to perform the contract between you and CCL in connection with use of our services.
8.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. DATA SECURITY
9.1. 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.
9.2. 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.
10. DATA RETENTION
FOR HOW LONG WILL WE USE YOUR PERSONAL DATA?
10.1. 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.
10.2. 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.
10.3. We retain your Contact, Identity and Transaction Data for 12 months after it is collected. Where applicable, we retain your Financial Data for three months after it is used to process a refund. The data associated with the SMS service is retained for 12 months after the relevant SMS message is sent before being securely deleted.
10.4. In some circumstances, you can ask us to delete your data. See the relevant section of the Glossary in paragraph 12 which sets out your data subject rights.
10.5. 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.
11. YOUR LEGAL RIGHTS
11.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can read more about these rights on the ICO website and in the Glossary in paragraph 12 below which describes your data subject rights.
11.2. If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
11.3. 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
11.4. 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
11.5. 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.
LAWFUL BASIS FOR PROCESSING
• 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.
INTERNAL THIRD PARTIES
• Other companies within the same group as CCL (that is, having common shareholders and directors) acting as processors and who are based in the UK and provide and use shared IT and system administration services and undertake leadership reporting.
EXTERNAL THIRD PARTIES
• Service providers acting as processors based in India who provide IT and system administration services.
• Secure data centre providers whose services we use as part of providing our services and the SMS service.
• Professional advisers acting as joint processors and controllers including lawyers, bankers, auditors and insurers based 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.
• Relevant regulators in the UK including but not limited to Ofcom, the Phone-paid Services Authority and the Information Commissioner’s Office.
YOUR LEGAL RIGHTS
You may have the right to:
• 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. 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.