uFlexReward’s Privacy Policy
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of our website or otherwise when you communicate or interact with us in the course of business.
This version of our privacy notice was last updated on 16th November 2020.
Controller
When you interact with us in the course of business or by looking at our website, UFlexRewardLimited is the data controller of your personal data. We are responsible for its security and for ensuring that we use it only for the purposes outlined in this Privacy Notice.
If you have any questions about this privacy notice or about your rights, please contact us.
Contact details
We areUFlexRewardLimited of No. 1 Poultry, London, EC2R 8EJ.
If you need to get hold of us for any reason in connection with your personal data, please email us through our website contact page or email us directly to [email protected]
- Contact Data includes name, business role, email address, phone number.
- Correspondence Data includes email correspondence, notes of meetings and notes of conversations.
- Usage Data includes information about how you use our website.
- Technical Data includes 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.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. We collect the majority of your data when you choose to give this to us on our website, by email, over the phone, in person at meetings or otherwise.
- Automated technologies or interactions (including analytical cookies). When you interact with our website, we use cookies to automatically collect your Usage Data and Technical Data. We collect information only from analytical cookies on our website to allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We don’t use any other non-essential cookies on this website. If you don’t want us to collect this sort of information about you, you can set your browser to refuse the Google Analytics cookie by following this link: Click here
4. 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 use of your data is necessary for our legitimate interests (or those of a third party) in the operation of our business and we have made an objective assessment that your interests and fundamental rights do not override those interests (for example to promote our services to you, to manage our relationship with you and to improve the service that we offer);
- In anticipation of or in accordance with an agreement that we have with you; or
- Where we need to comply with a legal or regulatory obligation; or
- Where you have provided us with specific consent (for example where you have agreed to the use of analytical cookies when you visit our website).
Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
5. Disclosures of your personal data
We will need to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
- Our service providers who provide us with IT management and system administration services.
- Website analytics companies who provide us with website functionality services.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
6. International transfers
We will only transfer your data to an overseas jurisdiction where there is sufficient legal basis to do so. Some of our marketing personal data is held in US data centres in industry leading CRM systems (due diligence has been conducted on the CRM providers and these data transfers rely on standard contractual clauses).
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. By law we have to keep your Contact and Correspondence Data for seven years after we stop working together. In some circumstances you can ask us to delete your data: (see below for further information).
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
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 about data protection before you approach the ICO so please contact us in the first instance.
You have the right in certain circumstances to:
- Request access to your personal data (a “data subject access request”).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data to you or to a third party.
For more information on these rights and when they apply is available here: Individual rights
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
