Introduction

Welcome to Retirement Security’s website privacy notice (‘Notice’).

Retirement Security respects your privacy and it is committed to protecting your personal data. This Notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and it will tell you about your privacy rights and how the law protects you.

This Notice is provided in a layered format so you can click through to the specific areas set out below.

Please use the Glossary at section 10 to understand the meaning of some of the terms used in this Notice.

Contents

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. Data security
7. Data retention
8. Your legal rights
9. Glossary

1. Important Information And Who We Are

The section of the privacy notice will provide you with a clear overview of the information being processed.

We aim to provide you with information on how Retirement Security collects and processes your personal data through your use of this website, including any data that you may provide to us through this website when you sign up to a product or service OR take part in a competition.

It is important that you read this Noticeor any other notice we may provide from time to time on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Notice supplements other notices and privacy policies and is not intended to override them.

Controller

Retirement Security is the data controller and responsible for your personal data (collectively referred to as [‘COMPANY’], ‘we’, ‘us’ or ‘our’ in this Notice.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Notice. If you have any questions about this Notice, including any requests to exercise [your legal rights], please [email protected] using the details set out below.

Contact Details

If you have any questions about this Notice or our privacy practices, please contact our [DPO OR data privacy manager] in the following ways:

Full name of legal entity: Data Protection Officer
Email address: [email protected]
Postal address: Unit 3, Wellesbourne Distribution Park, ​Loxley Road, ​​Warwick CV35 9JY.
Telephone number: 01789 292952

You have the right to make a complaint at any time to the Information Commissioner’s Office (‘ICO’), the regulator 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.

Changes to the Notice and Your Duty to Inform Us of Changes

We keep our Notice under regular review. This version was last updated on 20th March 2023.

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 [email protected]

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their content or practices. We are not responsible for any data that they may collect from you. When you leave our website, we encourage you to read the Notice of every website you visit.

2. 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].
• 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.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.

We do not collect any sensitive 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.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:-
  
  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey.
• Third parties or publicly available sources. We may share/ receive personal data about you from various third parties [and public sources] including:-
• • Law enforcement/statutory body.
  • Offsite document storage procedure.
  • Regulators such as theHomes England and the Care Quality Commission.
  • IT/Systems provider.

4. How We Use Your Personal Data

We will only use your personal data as prescribed by UK GDPR 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 we 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.
• To inform you of any Annual General Meetings (AGM) or Special General Meetings (SGM).
• Where we need to comply with a legal obligation imposed on us.
• Engagement from a statutory body, law enforcement agency or solicitor.

We will always obtain consent from you and rely on this as your legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us [email protected]

Purposes For Which We Will Use Your Personal Data

We have set out below, in the list below, a description of all the ways we plan to 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.

We may process your personal data for more than one purpose. When the purpose of processing changes we may rely upon a different lawful basis depending on the new purpose for which we are processing your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the list below.

Purpose/Activity: To register you as a new customer
Type of data:
(a) Identity
(b) Contact
Lawful basis for processing including basis of legitimate interest:
(a) Consent obtained directly from you

Purpose/Activity: To process and deliver you a service including:
(a) Manage payments, fees and charges
Type of data:
(a) Identity
(b) Contact
(c) Financial
(d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
(a) Consent obtained directly from you

Purpose/Activity: To manage our relationship with you which will include:
(a) Notifying you about changes to our terms of Notice
(b) Asking you to leave a review or take a survey
(c) We will regularly check that the information we hold on file is accurate and up to date
Type of data:
(a) Identity
(b) Contact
(c) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
(a) Consent obtained directly from you

Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey
Type of data:
(a) Identity
(b) Contact
(c) Marketing and CommunicationsLawful basis for processing including basis of legitimate interest:
(a) Consent obtained directly from you

Purpose/Activity: To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data:
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data:
(a) Identity
(b) Contact
(c) Marketing and Communications
(d) Technical
Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data:
(a) Technical
(b) Usage
Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy

Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data:
(a) Identity
(b) Contact
(c) Technical
(d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where you may have provided us consent initially to receive marketing from us, we understand that at anytime, you may wish to unsubscribe from receiving marketing emails in the future. Should you wish to unsubscribe from receiving email marketing from Retirement Security, please email: [email protected]

You will receive marketing communications from us if you have requested information from us or engaged with us on using our services and have not opted out of receiving that marketing.

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 necessary we will identify a new legal basis. Please contact us if you require an explanation of how the processing for the new purpose is compatible with the original purpose.

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.

5. Disclosures Of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

• External Third Parties as set out in the [Glossary].
• 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 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. 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.

7. Data Retention

How Long Will You Process My Personal Data For?

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.

We will hold your information as long as you are a resident with us or reside in the property. Once the property has been sold, Retirement Security will retain your personal information for 3 months after the completion of the sale and then your personal data will be deleted.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise 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.

8. Your Legal Rights

Under certain circumstances, data protection law provides you with rights in relation to your personal data.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected]

Subject Access Rights

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly manifestly excessive, manifestly unfounded or repetitive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You

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.

Time Limit To Response

We respond to all requests without undue delay and within one calendar month of receipt. 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.

9. Glossary

Lawful Basis

Generally, we will seek and record that you have consented to our processing of your personal data. In some circumstances we will rely upon other legal basses.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

Internal Third Parties

• Other companies in the Retirement Security group are Court Manager Group who are acting processors and are based within the UK and provide administration services to Retirement Security group.
• Internal consulting company who facilitate the IT and running of the website.
• Content/logo provider who oversees the content of the website.

External Third Parties

• Service providers acting as processors based within the UK who provide IT and system administration services.
• Internal consulting company who facilitate overall running and IT of the website.
• Content/logo provider who oversees the content of the website.

Your Legal Rights

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.