1.4. Our website incorporates privacy controls which aﬀect how we will process your personal data.
1.5. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via account settings within the App.
1.7. In this policy, “we”, “us” and “our” refer to Pension Jar.
2. ABOUT US
3. INFORMATION WE MAY COLLECT FROM YOU
3.1. During the course of opening a Pension Jar account, the information you give to us may include your name, address, email address, phone number, date of birth, National Insurance number, bank account and other ﬁnancial details, copies of personal identiﬁcation documents (such as your passport or driving licence) and photographs or other descriptions of your likeness. You may also provide us with certain information by ﬁlling in other forms, entering competitions or promotions or by corresponding with us by phone, email, or text message.
3.2. When you visit our website or use our App we may collect or receive your IP address, URL, browser information, plug-in types, operating system and platform as well as your login information. We work closely with third parties (for example: business partners, technical, payment and delivery service providers, advertising networks, tracking and analytics providers (including Google), search information providers, lead generation agencies and credit reference agencies) and may receive information about you from them, such as your clickstream through our website and App, the products you viewed and the page interactions.
4. WHAT WE USE YOUR INFORMATION FOR
4.1. We use the information we collect about you to:
a. Verify your identity and to conduct anti-money laundering checks;
b. provide you with the products and services you have requested;
c. carry out our contractual obligations in relation to contracts entered into with you or with our business partners and service providers;
d. notify you about changes to our products or services;
e. ensure that content from our website and our App is presented in the most effective manner for you and for your devices;
f. administer our website and App and for internal operations such as troubleshooting, data analysis, testing and research purposes;
g. help maintain the safety and security of our website and App;
h. make suggestions to you (and other customers) about our products or services and to send such information via email, SMS message, targeted social media and our in-App secure notiﬁcation centre; and
i. measure or understand the effectiveness of advertising we send to you (and other customers) and to deliver relevant advertising to you
5. PROCESSING OF DATA
5.1. We will access, use, and share the Information as required to fulﬁl our contractual obligations to you or subsequent requests for support by you.
5.2. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
a. Google Analytics, please visit https://www.google.com/analytics
5.4. We may process your account data (“account data”). The account data may include your name and email address. The account data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
5.5. We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
5.6. We may process information that you provide to us for the purpose of subscribing to our email communications (“notiﬁcation data”). The notiﬁcation data may be processed for the purposes of sending you the relevant notiﬁcations and/or newsletters. The legal basis for this processing is consent.
5.7. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
5.8. We may process any of your personal data identiﬁed in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
5.9. We may process any of your personal data identiﬁed in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
5.10. In addition to the speciﬁc purposes for which we may process your personal data set out in this Section 5, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. DISCLOSING YOUR PERSONAL DATA
6.1. Advertisers and advertising networks that require the information to select and serve relevant adverts to you and others. We do not disclose information about identiﬁable individuals to our advertisers, but we may provide them with anonymised or aggregate information about our users.
6.2. Analytics and search engine providers that assist us in the improvement and optimisation of our site (for example Google for the purpose of its Google Analytics service).
6.3. If we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective seller or buyer of such business or assets.
6.4. Or if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
7. SECURITY OF YOUR INFORMATION
7.1. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website or App. Transmission is at your own risk.
7.2. Where we have given you, or where you have chosen, a password or personal identiﬁcation number (PIN) which enables you to access certain parts of our App, you are responsible for keeping this password or PIN conﬁdential. We ask you not to share this password or PIN with anyone.
7.3. The hosting facilities for our website are situated in the UK. Or if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
7.4. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
8. RETAINING AND DELETING PERSONAL DATA
8.1. Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose.
8.2. We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8.3. To request erasure of your personal data please contact us at firstname.lastname@example.org.
9.2. If appropriate we will notify you by email about changes. Remember, you will be bound by this policy.
10. YOUR INFORMATION RIGHTS
10.1. You have the following rights in relation to your Data:
a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase – the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
e. Right to data portability – the right to request that we move, copy or transfer your Data.
f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
10.2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: email@example.com