Programme (which we call the "Scheme" in this policy).
This policy together with our terms and conditions
of membership sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Please note that we comply with the Data Protection Act 1998 and have notified the Information Commissioner of the purpose for which we use data.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Adaptive Affinity Limited of Wisteria Grange Barn, Pikes End, Pinner, HA5 2EX and our Registration number with the Information Commissioner's Office is ZA577032.
What information is collected?
We gather two types of information.
The first type of information is the personally identifiable information ("Personal Information") that you expressly provide when you enrol as a member and when you use the services in the Scheme. This information includes (without limitation) your name, postal address, e-mail address, and date of birth or some other unique personal identifier that we can use to confirm sales or billing information. Occasionally, we may request other information from you that may be used to confirm enrolment or update your account. If you contact us, we may keep a record of that communication. From time to time, we may also offer you optional surveys that may ask you for your opinions or demographic data (e.g. age and gender) so that we can improve our Scheme and Benefits.
The second type of information is technical and statistical information ("Statistical Information") that is collected automatically whenever you visit the web site or web pages associated with the Scheme ("Website"). This type of information may include things such as your IP address, operating system, type of browser and Website activity. We collect this data to help us improve the quality of our Website and make your visits to the Website easy, convenient and meaningful.
Who is collecting the information?
The Website and the Scheme is marketed and operated by Adaptive Affinity Limited, a leading marketing solutions company registered in England.
The Member Website is operated by Adaptive Affinity Limited. The Scheme is operated by: Adaptive Affinity Limited; and TransUnion International UK Limited.
How do we use the information collected?
Adaptive Affinity Limited uses Personal Information to service your membership. We may send you additional membership information such as updates about our Scheme and special offers. By way of another example, we use your Debit/Credit card information to bill you for the membership fees. Another example: We may use your e-mail address to notify you of Scheme updates, special offers and promotions. If you prefer not to receive e-mail notifications from us, you can change, modify or update your preference simply by sending us an e-mail from the "Contact" page of the Website or by accessing the "Marketing Preferences" menu option on the website. Alternatively you can call or write to us on the contact details below.
Adaptive Affinity Limited and TransUnion International UK Limited also collect information which will help TransUnion International UK Limited to verify your identity, such as email addresses, usernames and passwords, along with other personal information which TransUnion International UK Limited will need in order to provide you with a copy of your credit report or credit score (if applicable). This will include, for example, your name, date of birth, your residential address and postcode. This information will be checked against external databases, such as the electoral roll and your credit report, to which TransUnion International UK Limited has access for this purpose. TransUnion International UK Limited (but not Adaptive Affinity Limited) will collect and store a record of the check as well as any additional information you provide, including (but not limited to) aliases, previous addresses and financial associations. TransUnion International UK Limited may disclose this information to authorised third parties through its credit referencing, fraud prevention and identification products.
Occasionally TransUnion International UK Limited may also ask you to provide documentation for the purpose of verifying your identity, such as utility bills or bank statements . TransUnion International UK Limited will only request this information when it needs to verify your current address. Any documentation is stored securely, and will be destroyed once verification is complete.
We use the Statistical Information that is automatically collected from your device whenever you visit the Website, to help us improve the Website and the member experience. From time to time we may disclose general statistical information about our Website and its visitors such as the number of visitors, the number and type of products purchased, etc. We do not disclose information about identifiable individual.
We may unless required by law delete any personal information that we hold of members that have cancelled within the free trial period and have not been billed. Please note that we are only able to delete personal information that we hold, and not those of our partners and TransUnion International UK Limited.
How do I change/modify my information?
You can change, modify or update your member information simply by sending us an e-mail from the "Contact" page of the Website or by accessing "My Account" section by logging into the website. Alternatively you can call or write to us on the contact details below.
Do you share personal information with third parties?
All information that is collected may also be shared with our Partners. Their use of that information will be governed by their own privacy policies (but in respect of any information transferred out of the EU, we will only transfer to any company who provides adequate safeguards for it).
All information that is collected may also be shared with TransUnion International UK Limited whose use of that information will be governed by its own privacy policies.
We may also share Personal Information with third parties who we employ to perform functions on our behalf. For example, we use a third party to verify and process your Debit/Credit card information in order to bill you. All third parties are contractually obligated to use your Personal Information only for the purpose for which it is given.
From time to time, we may share Personal Information with our partners who are offering programmes or benefits that we think will be of interest to you. If you prefer to have your personal information shared with our affiliates and or partners, you may want to opt-in to receiving e-mails by selecting the check box on the enrolment page.
We may also disclose your Personal Information when required by law or in the good-faith belief that such action is necessary in order to conform to the law or other legal obligations or processes.
As we continue to develop our business, we may buy or sell assets. In such transactions, customer information generally is one of the transferred business assets. Also, in the unlikely event that our company or substantially all of its assets are acquired, customer information will of course be one of the transferred assets. In the event that customer information is transferred as described in this paragraph, members will be notified via e-mail and given the opportunity to opt-out of having their personal information transferred to any new entity.
We will not disclose your personal information to anyone other than those parties set out within this policy without your consent.
What are Cookies and how do you use them?
How do you secure member information?
We work to protect the security of your Personal Information during transmission by using Secure Socket Layer (SSL). When you place an order online, the SSL technology encrypts your information before it is sent to us over the Internet. This protects your Debit/Credit card information from being read while it is transferred through cyberspace. When we receive the information, the information is kept encrypted until we are ready to process your request. You will see a padlock on your browser address bar, indication that your transaction is secure. In addition, we meet all of the stringent requirements of the Comodo ECC Certification Authority for all online transactions.
An internal security policy with respect of the confidentiality of customer data allowing access only to those employees or third parties who have a need to know such information for the purpose of effectively delivering services by means of user login and password requirements. We routinely evaluate our data security practices to identify security threats or opportunities for improvement.
Physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information and, as a result, we may sometimes request proof of identity from you before we disclose personal information to you.
You are responsible for protecting against unauthorised access to your password and to your devices.
Do these same policies apply to third party web sites that I access through the Scheme?
Your Rights to see your personal data
You have the right to see the personal data (as defined in the Data Protection Act 1998) that we keep about you, on receipt of a written request, verification of your identity, and if required payment of a fee. If you are concerned that any of the personal information we hold on you is incorrect, please contact us as set out in the "How do I contact you?" section below.
How do I contact the Web site?
If you have any questions about the practices of our Website or Scheme or your dealings with our Website or Scheme, you can contact: Credit Confidential®
, Wisteria Grange Barn, Pikes End, Pinner, HA5 2EX. Telephone number: 0333 344 1785. Email: firstname.lastname@example.org
Last updated 23 April 2019