• We may collect personal information about you from a number of sources, including the following:
  1. From you when you agree to take a service or product from us, in which case this may include your contact details, date of birth, how you will pay for the product or service and your bank details.
  2. From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services.
  3. As you interact with this Website, we may automatically collect technical information about your equipment, browsing actions and patterns (such as your 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). We may collect this personal information by using cookies and other similar technologies.
  4. From documents that are available to the public, such as the electoral register.
  5. From third parties to whom you have provided information with your consent to pass it on to other organisations or persons – when we receive such information we will let you know as soon as is reasonably practicable.
• If you refuse to provide information requested, then if that information is necessary for a service we provide to you we may need to stop providing that service.
• If at any point you think we’ve invited you to provide information without explaining why, feel free to object and ask for our reasons.

2. Using your personal information
   • Data protection, privacy and security are important to us, and we shall only use your personal information for specified purposes and shall not keep such personal information longer than is necessary to fulfil these purposes. The following are examples of such purposes. We have also indicated below which UK GDPR justification applies, however it will depend on the circumstances of each case.
     1. To help us to identify you when you contact us. This will normally be necessary for the performance of our contract.
     2. To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the personal information you’ve provided and/or any information we hold about you and personal information from third party agencies (including credit reference agencies). We will only use your information for this purpose if you agree to it.
     3. To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future. This will often be necessary, but sometimes the improvements will not be necessary in which case we will ask whether you agree.
     4. To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information. This will sometimes require that you consent, but will sometimes be exempt as market research.
     5. To help to prevent and detect fraud or loss. This will only be done in certain circumstances when we consider it necessary or the law requires it.
     6. To allow us to contact you by written electronic means (such as email, text or multimedia messages) about products and services offered by us where:
        1. these products are similar to those you have already purchased from us,
        2. you were given the opportunity to opt out of being contacted by us at the time your personal information was originally collected by us and at the time of our subsequent communications with you, and

• you have not opted out of us contacting you.

1. To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners where you have expressly consented to us doing so.
2. We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.
   1. Before doing that, we will always tell you of our intentions and of the specific purpose in making the recording. Sometimes such recordings will be necessary to comply with the law. Alternatively, sometimes the recording will be necessary for our legitimate interest, but in that case we’ll only record the call if our interest outweighs yours. This will depend on all the circumstances, in particular the importance of the information and whether we can obtain the information another way that’s less intrusive.
   2. If we think the recording would be useful for us but that it’s not necessary for our legitimate interest, we’ll ask whether you consent to the recording, and will provide an option for you to tell us that you consent. In those situations, if you don’t consent, the call will either automatically end or will not be recorded.
3. When it’s required by law, we’ll check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we intend to record this.

• We will not disclose your personal information to any third party except in accordance with this Policy, and then only in one of the following circumstances:
  1. They will be processing the data on our behalf as a data processor (where we’ll be the data controller). In that situation, we’ll always have a contract with the data processor as set out in the UK GDPR. This contract provides significant restrictions as to how the data processor operates so that you can be confident your data is protected to the same degree as provided in this Policy.
  2. Sometimes it might be necessary to share data with another data controller. Before doing that we’ll always tell you. Note that if we receive information about you from a third party, then as soon as reasonably practicable afterwards we’ll let you know; that’s required by the UK GDPR.
  3. Alternatively, sometimes we might consider it to be in your interest to send your information to a third party. If that’s the case, we’ll always ask whether you agree before sending.
• Where you give us personal information on behalf of someone else, you confirm that you have provided them with the information set out in this Policy and that they have not objected to such use of their personal information.
• In connection with any transaction which we enter into with you:
  1. We may carry out one or more credit checks.
  2. We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records may also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.
  3. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.
  4. If you need details of those credit agencies from which we obtain and with which we record information about you, please write to our Data Protection Manager as detailed in clause 4.
  5. We may need to transmit the payment and delivery information provided by you during the order process for the purpose of obtaining authorisation from your bank.
• We may allow other people and organisations to use personal information we hold about you in the following circumstances:
  1. If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case personal information held by us, about our customers, will be one of the transferred assets.
  2. If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.
  3. We may employ companies and individuals to perform functions on our behalf and we may disclose your personal information to these parties for the purposes set out above. Third parties we may share your personal information with include:
• Our Principal, Movo Partnership Ltd
• The insurers with whom we work with

 From time to time, these other people and organisations to whom we may pass your personal information may be outside the European Economic Area. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy and the UK GDPR. We require all third-party service providers processing your personal information for us (as our data processor) to respect the security of your personal data and to treat it in accordance with the law. We do not allow them 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.

3. Protecting information
   • We have strict security measures to protect personal information.
   • We work to protect the security of your information during transmission by using appropriate technology to encrypt information you input.
   • We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
   • It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
4. The internet
   • If you communicate with us using the internet, we may occasionally email you about our services and products. When you first give us personal information through the Website, we will normally give you the opportunity to say whether you would prefer that we don’t contact you by email for that purpose. You can also always send us an email (at the address set out below) at any time if you change your mind.
   • Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.