PERSONAL INFORMATION WE MAY COLLECT FROM YOU
You may provide some information to us, for example when you enquire for or make an application for our services, register to use and/or use any of our services, by filling in forms on one of our applications or websites, participating in one of our promotional events or by corresponding with us by phone, email, chat or otherwise. We may collect some of it through automatic means. We may also obtain data about you from third parties, like credit reference and fraud prevention agencies. For more details and examples, please review the comprehensive privacy notice, which also explains our use of any biometric, sensitive or special category personal data.
USES MADE OF THE PERSONAL INFORMATION
We may use personal information for the following purposes:
To verify your identity and establish and manage your user account
As part of providing services, or information about our services, to you, we will need to verify your identify to set you up as a user and we will need to use those details in order to effectively manage your user account with us to ensure that you are getting the best possible service from us. This may include third parties carrying out credit or identity checks on our behalf.
To provide you with products and services, or information about our products and services, and to review your ongoing needs
Once you open a user account with us, we will need to use your personal information to perform our services to you. It is also in our legitimate interests to ensure that we are providing the best products and services so we may periodically review your needs to ensure that you are getting the benefit of the best possible products and services from us.
To help us improve our products and services, including customer services, and develop and market new products and services
We may from time to time use personal information provided by you through your use of the services and/or through customer surveys to help us improve our products and services. It is in our legitimate interests for us to use your personal information in this way to ensure that we provide you with the best products and services we can.
To form a profile about you
We may from time to time use personal information about you to form profiles about you so that we can understand you and provide the very best products and services we can. We may also make decisions about you through automated profiling or automated credit checks which may affect your ability to use our services. It is in our legitimate interests for us to use your personal information in this way to ensure that we provide you with the best products and services we can.
To investigate or settle enquiries or disputes
We may need to use personal information collected from you to investigate issues and/or settle disputes with you as it is in our legitimate interests to ensure that issues and/or disputes get investigated and resolved as quickly and efficiently as possible.
To comply with applicable law, court order or other judicial process
We may need to use your personal information to comply with applicable law, court order or other judicial process, or the requirements of any applicable authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.
To send you surveys
From time to time, we may send you surveys as part of our customer feedback process and it is in our legitimate interest to ask for feedback to ensure that we provide the best service to you. All responses to any survey we send out will be aggregated and depersonalised before survey results are shared with any third parties.
Our application, website and emails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
Marketing by us
We may use your personal information to send you marketing communications by email or phone or other agreed forms (including social media campaigns) to ensure that you are always kept up to date with our latest products and services. Where we send you marketing communications we will either do so as it is in our legitimate interest or with your consent.
Internal business purposes and record keeping
We may need to process your personal information for internal business and research purposes and record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your obligations under any contract you have entered into with us.
If we undergo a corporate restructure or part or all of our business is acquired by a third party, we may need to use your personal information in association with that restructure or acquisition. Such use may involve disclosing your details as part of a due diligence exercise. It is our legitimate interest to use your information in this way provided we comply with any legal obligation we have to you.
DISCLOSURE OF YOUR PERSONAL INFORMATION
We will not disclose your personal information to anyone except as described in this notice.
We may share your personal information with any affiliated companies.
Your personal information (as necessary, but generally limited to full name and email address) may be shared with the recipient/sender of a payment in the context of the specific relevant transaction.
We may share your personal information with third parties to provide you with the products we offer, including service providers and credit reference agencies.
We may also share your personal information with third parties, including our or other applicable regulators and third parties you may have had dealings with, to prevent crime and reduce risk, if required to do so by law, where we deem it appropriate to do so, to respond to legal process, for the purpose of investigating a breach of third-party terms of business, or to protect the rights or property of us, our customers or others.
If we have given you (or if you have chosen) a password, access code or any other secure means or access or authentication which enables you to access certain parts of our site, you are responsible for keeping this password confidential and complying with our instructions. You must not share credentials with anyone else, and you authorise us to act upon instructions and information from any person that enters your credentials.
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 data transmitted to our site, unless you are communicating with us through a secure channel that we have provided. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation (GDPR). Residents of the United Kingdom and all other countries have certain data protection rights under the Data Protection Act 2018. We aim to take reasonable steps to allow you the right to correct, amend, delete, or limit the use of your personal information. The information about these rights that might be available to you in relation to the personal information we hold about you is set out below.
Please note that we may ask you to verify your identity before responding to you exercising any of the rights set out herein.
You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact the Information Commissioner’s Office or your local data protection authority in the European Economic Area (EEA).
Right to access, update or to delete the information we have on you
Whenever made possible, you can access, update or request deletion of your personal information directly within your user account settings section. If you are unable to perform these actions yourself, please contact us to assist you. If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable administration fee.
The right of rectification.
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
The right to withdraw consent
You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it or you withdraw your consent (where applicable) provided that we have no legal obligation to retain that data. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
The right of restriction
You can ask us to restrict the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
The right to data portability
You have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
The right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
processing your personal information for direct marketing; or
processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.
Automated decision-making and profiling
If we have made a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to use the services or has another significant effect on you, you can ask to not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us. Even where a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention.
LEGAL BASIS FOR PROCESSING
We will generally process your personal information based on one of the following grounds:
On the basis of your consent, for example to send you marketing messages to the extent consent is required by law;
Where necessary to enter into a contract with you and perform our obligations under that contract;
Where we have a legitimate interest, subject to such processing not overriding your own rights and freedoms;
Where we have a legal obligation to collect your personal information or otherwise need your personal information to protect your vital interests or those of another person; or
exceptionally, when necessary in the public interest, for example when law enforcement agencies request information to investigate a crime.
CHANGES TO OUR PRIVACY NOTICE
Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.
All comments, queries and requests relating to our use of your personal information are welcomed. If you wish to exercise any of your rights or receive further information, you can contact as follows:
OpesJet Holdings Ltd.
Kemp House, 160 City Road, EC1V 2NX London, United Kingdom