“We” are Phoenix Management Group Limited, a company registered in England and Wales under company number 10872412. Our registered office address is Unit 3 Owen House Farm Wood Lane, Mobberley, Knutsford, England WA16 7NY. We are the data controller for the purposes of the Data Protection Act 2018, the EU General Data Protection Regulation (GDPR) and any other data protection legislation applicable in the UK from time to time.
If you have any questions about your privacy on our website or our use of your personal data, please contact us.
This website is not intended for children and we do not knowingly collect data relating to children under the age of 13. We do not knowingly collect or solicit personal data from children under the age of 13 through this website.
If we learn that we have collected or solicited personal data from a child under the age of 13 we will promptly delete that information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us.
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.
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.
4. 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 as 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 billing address, delivery 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 and other details of products and services you have purchased from us.
- Technical Data your device IP address, domain name, identifiers associated with your device, device and operating system type and characteristics, web browser characteristics, language preferences, clickstream data, your interactions with our website (such as the web pages you visit, links you click, videos you watch and features you use), the pages that led or referred you to our website, dates and times of access to our website, and other information about your use of our website by way of browser cookies, web beacons, device identifiers, server logs, and other technologies.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, 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 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.
5. How Your Personal Data is Collected
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:
- 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 feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by way of browser cookies, web beacons, device identifiers, server logs, and other technologies. This information helps us to distinguish you from other users of our website. These can streamline your online experience by saving you from re-inputting some information and also allows us to make improvements to our website. Please see clause 9 for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
- Technical Data from analytics providers such as Google based outside the EU;
- Technical Data from advertising networks;
- Technical Data from search information providers;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from data brokers or aggregators; and
- Identity and Contact Data from publicly available sources including from but not limited to Companies House and the Electoral Register based inside the EU.
6. 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; and
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.
7. Purposes for Which We Will Use Your Personal Data
We take data protection law seriously, we have set out below exactly how and why we 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 below.
We may collect the following personal data in order to perform a contract with you, comply with a legal obligation and/or as a necessity to our legitimate interests:
- collect your Identity, Contact and Technical Data to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- collect your Identity, Contact, Profile, Usage, Marketing and Communications and Technical data to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
- collect your Technical and Usage Data to use data analytics to improve our website, products/services, marketing, customer relationships and experiences; and
- collect your Identity, Contact, Technical, Usage, Profile, and Marketing and Communications Data to provide or make suggestions and recommendations to you about goods or services that may be of interest to you.
We always want to offer the best services and experience that we can. Sometimes this means we may use your information to find ways that we can improve what we do, or how we do it. In this context, we will rely on the lawful basis of legitimate interests and will only use your information where it is necessary so that we can:
- personalize your experience on our website;
- provide our services to you;
- market our services to you;
- respond to your requests and inquiries;
- operate, evaluate and improve our business (including developing new services; enhancing and improving our services; analysing our services; managing our communications; performing data analytics and market research; and performing accounting, auditing and other internal functions);
- protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
We want to stay in touch with you. Sometimes we may need to use the information that we have about you in order to respond to your questions or let you know about important changes. We have a legitimate interest in keeping in touch with our customers and other contacts.
We may contact you to let you know about important changes to our business, services or policies, and to respond to any communications you send us, including where you email, write to us, or contact us via social media.
We may use your personal data where it is necessary for us to do so in order to meet our legal obligations or to detect and prevent fraud, money-laundering and other crimes.
We may use your personal where it is necessary to protect your interests, or the interests of others, in accordance with our legal obligations and the pursuit of legitimate interests. This may include in the event of criminality such as identity theft, piracy or fraud.
We may need to use your personal data in order to meet our legal obligations, including tax and other regulatory requirements, and to ensure that any local registration requirements in the applicable jurisdictions are satisfied.
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 from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
A web beacon, also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We and our third-party service providers may use beacons or pixels in emails to help us track response rates, identify when our emails are accessed or forwarded and for other purposes as listed below.
When you use our website we may obtain certain information by automated means, such as browser cookies, web beacons, device identifiers, server logs and other technologies. The information we obtain in this manner may include your device IP address, domain name, identifiers associated with your device, device and operating system type and characteristics, web browser characteristics, language preferences, clickstream data, your interactions with the website (such as the web pages you visit, links you click, videos you watch and features you use), the pages that led or referred you to our website, the dates and times you accessed our website and other information about your use of our website.
Using these technologies helps us to:
- remember your information so you do not need to re-enter it;
- track and understand how you use and interact with our website;
- tailor our website around your preferences;
- measure the usability of our website;
- understand the effectiveness of our communications; and
- otherwise manage and enhance the functionality of the website.
10. 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.
11. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in Clause 7 above.
We may share your data with selected third parties. For example, we may share your information with:
- internet hosting providers and data management systems, to host the website, related infrastructure, services and applications;
- third party service providers to assist with market research, customer satisfaction surveys and testimonials and support services; and
- contact management systems to send emails, instant messages, social media messages and SMS messages.
There are also certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:
- required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings;
- necessary to protect the safety of our employees, our property or the public;
- necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction; or
- proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved.
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.
12. 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.
13. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by contacting us.
14. Your Legal Rights
If you require any further information about your rights as explained below, or if you would like to exercise any of your rights, please contact us.
You have the right to be informed. We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to comply with this right.
You have the right to access your personal data. You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:
- why we have been using your information;
- what categories of information we were using;
- who we have shared the information with; and
- how long we envisage holding your information.
In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold. The first copy of your information that you request from us will be provided free of charge, if you require further copies we may charge an administrative fee to cover our costs.
You have the right to correct any inaccurate or incomplete personal data. Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can contact us so that we can correct our records.
You have the right to be forgotten. There may be times where it is no longer necessary for us to hold personal information about you. This could be if:
- you object to us using your information and we have no overriding reason to keep using it;
- the information is no longer needed for the original purpose that we collected it for;
- you withdraw your consent for us to use the information (and we have no other legal reason to keep using it);
- we have used your information unlawfully; or
- we are subject to a legal requirement to delete your information.
In the situations listed in the bullet points immediately above, you have the right to have your personal data deleted. If you believe on of these situations applies to you, please contact us.
You have the right to have your data transferred to you or a third party in a common format. Also known as data portability, you have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way.
If you would like us to transfer a copy of your data to you or another organisation in a structured, commonly use and machine-readable format, please contact us. There is no charge for you exercising this right.
You have the right to object to direct marketing. You can tell us at any time that you would prefer that we do not use your information for direct marketing purposes. If you would not like to receive any direct marketing from us, please contact us or use the links provided in any of our marketing communications.
You have the right to object to us using your information for our own legitimate interests. Sometimes, we use your personal information to achieve goals that will help us as well as you. This includes when we tell you about products or services that are similar to ones you have already bought; when we use your information to help us make our business better; and when we contact you to interact, communicate or to let you know about changes we are making.
We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes.
You have the right to restrict how we use your personal data. You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:
- you have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this;
- you have objected to us using your information for our own legitimate interests and we are in the process of considering your objection;
- we have used your information in an unlawful way, but you do not want us to delete your data; or
- we no longer need to use the information, but you need it for a legal claim.
You have rights related to automated-decision making and profiling. Any automated decision-making or profiling we undertake is solely for the purpose of tailoring the information which we provide to you. We will not use automated decision-making or profiling to make any decisions which will have a legal effect upon you or otherwise significantly affect you, and you have the right not to be subject to such decisions. If you have any concerns or questions about this right, please contact us.
If you wish to make a complaint about our collection or use of your personal data, please contact us in the first instance so that we may seek to resolve your complaint.
You have the right to lodge a complaint with the supervisory authority for your jurisdiction. If you are based in the UK you may contact the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK. Please visit the ICO website for further information or should you wish to lodge a complaint with the ICO.
16. Contact Us