Legal basis for processing your information
Under applicable Data Protection Law we may only process your Information if we have a “legal basis” (i.e. a legally permitted reason) for doing so. For the purposes of this Policy, our legal basis for processing your Information is:
your consent (for which see below); or
subject to your rights set out below (see “Your Rights”), the legitimate interest of providing services to our users through the Site, which requires the processing of your Information to enable us to provide these services.
Your consent to processing
As noted above, you will be required to give consent to the processing of your Information as set out in this Policy. We will seek this consent from you when you first submit Information to or through the Site. If you do not consent to such processing you should not submit any Information to or through the Site.
If you have previously given consent you may freely withdraw such consent at any time. You can do this through your account on the Site or by notifying us in writing using our contact details below.
If you withdraw your consent, and if we do not have another legal basis for processing your information (see above), then we will stop processing your Information. If we do have another legal basis for processing your information then we may continue to do so subject to your legal rights (for which see “Your Rights” below).
Please note that if we need to process your Information in order to operate the Site and/or provide our services, and you object or do not consent to us processing your Information, the Site and/or those services may not be available to you.
Our Use of Your Personal Information
The LifeStyle Group website does not store or capture personal information about you when you visit it, it merely records traffic information. This means information about all of our visitors collectively, for example how many visits the website receives. In order to respect our vistors’ rights of privacy, this information is anonymous and no individual visitor can be identified from it.
We will only collect personal information about you if you send us an e-mail, or if you complete an enquiry, contact, registration, service request or application form on the website. The type of information being collected will be relevant to the specific enquiry and apparent from the layout of the form and the information in the related webpages.
We take all reasonable precautions to protect our visitors’ information, both on and off line. If your personal information changes, please let us know and we will correct, update or remove any information that we hold about you on our active databases. We may however need to retain archive copies of that personal information for legal or audit purposes. If you have any queries regarding the way in which LifeStyle Group handles data collected from you on this website, please contact us.
Marketing and opting out
If you have given permission, we and our group companies may wish to provide you with information by email about special features of the Site or any of our other services we think may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to use your data for such purposes. If you would rather not receive this marketing information, or you no longer wish to receive it, you can always decline and/or opt out (see below).
If you have given permission, we may also want to contact you by email to provide you with information we think may be of interest to you from carefully selected third parties. Again, we will inform you (before collecting your data) and seek your permission if we intend to use your data for such purposes. If you would rather not receive such third party information from us, or you no longer wish to receive it, you can always decline and/or opt out (see below).
If you have given permission, we may share your personal data with carefully selected third party organisations and business partners and they may contact you directly (unless you have asked them not to do so) by email about services that may be of interest to you. As above, we will inform you (before collecting your data) and seek your permission if we intend to disclose your data to third parties for such purposes. If you prefer not to receive direct marketing communications from our business partners, or you no longer wish to receive them, you can decline and/or opt out at any time (see below).
You have the right at any time to ask us, or any third party, to stop processing your Information for direct marketing purposes. If you wish to exercise this right, you should contact us by sending an email to firstname.lastname@example.org, or contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request. Alternatively you can follow the unsubscribe instructions in emails you receive from us or them.
When might we disclose your Personal Information to others?
Please be assured that except for the reasons listed below, we will not disclose your Personal Information to any other party.
We may disclose your Information (including Personal Data) to:
- other companies within our group;
- our agents and service providers who help us to provide our services (and we will ensure they have appropriate measures in place to protect your Information);
- third parties you wish to allow to access to your Information through the Site;
- law enforcement agencies in connection with any investigation to help prevent unlawful activity; and
- our business partners in accordance with the ‘Marketing and opting out’ section above.
- If our business is sold or integrated with another business your Information may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
- We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Site. In such circumstances we do not disclose any information which can identify you personally.
Agents Partners and Service Providers
We use contracted third parties and partners to handle communication, enquiries and in the provision of our services. These are:
Money Life Living Ltd, The Answer Centre, Grupo Aval, BMI Seguros
Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be randomly monitored and/or recorded to protect the interests of our business and our customers. This includes – for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that LifeStyle Group representatives comply with legal obligations and LifeStyle Group policies and procedures (including our customer relations practices).
If you are an individual, this section sets out your legal rights in respect of any of your Personal Data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details below) giving us enough information to identify you and respond to your request.
- You have the right to request information about Personal Data that we may hold and/or process about you, including: whether or not we are holding and/or processing your Personal Data; the extent of the Personal Data we are holding; and the purposes and extent of the processing.
- You have the right to have any inaccurate information we hold about you be corrected and/or updated. If any of the Information that you have provided changes, or if you become aware of any inaccuracies in such Information, please let us know in writing giving us enough information deal with the change or correction.
- You have the right in certain circumstances to request that we delete all Personal Data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the Personal Data for legal compliance purposes. If this is the case we will let you know.
- You have the right in certain circumstances to request that we restrict the processing of your Personal Data, for example where the Personal Data is inaccurate or where you have objected to the processing (see below).
- You have the right to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you we will let you know.
- You have the right in certain circumstances to object to processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests.
- You have the right to object to direct marketing, for which see (‘Marketing and opting out’) above.
We are happy to provide you with details of the Personal Information, which we process about you. To protect our customers’ data, we follow strict storage and disclosure procedures, which means that we will require proof of identity from you prior to disclosing such information. We may charge a small administration fee in relation to any requests for access to personal information. Please direct any such request to – Money Life Living Ltd, Admin 4607, Post Box 6945, London W1A 6US
Please help us to keep your Personal Information current and accurate by contacting us if your Personal Information is or becomes inaccurate and/or out-of-date.
As you may be aware, no data transmission over the internet can be entirely secure. As a result, while we will always use reasonable endeavours to protect your Personal Information, we cannot guarantee the security of your Personal Information and the use of our site (including the e-mail facilities) is at your own risk.
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