Money Bubble ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website “www.moneybubble.co.uk” (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Cookies”||means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.|
|“Data Protection Regulation”||means the Data Protection and Privacy Electronic Communications (EU Exit) Regulations 2019 by EU Regulation 2016/679 General Data Protection Regulation (“UK GDPR”) Data protection act UK 2018.|
|“Personal Data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined in the Data Protection and Privacy Electronic Communications (EU Exit) Regulations 2019 by EU Regulation 2016/679 General Data Protection Regulation (“UK GDPR”).|
|“We/Us/Our”||means Money Bubble, a limited company registered in England under company number 11785059, whose registered [enter address registered at Companies House] and trading address is [enter trading address if different to registered address].|
|“EU”||means the European Union.|
|“UK”||means the United Kingdom.|
2. Information About Us
3. What Does This Policy Cover?
4. Your Rights
As a data subject, you have the following rights under the Data Protection Regulations, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us)
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time,but if you would like Us to delete it sooner, please contact Us
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
- if you submit a request against any of the rights, this will be reviewed and responded to in within 30 days but there’s no guarantee some rights can be met (e.g. can’t automatically delete data that has to be retained for legal reasons).
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
1. Full name
2. Home address and residential status;
3. Date of birth;
5. Business/company name;
6. Job title/profession;
7. Contact information such as email addresses and telephone numbers;
8. Demographic information such as postcode, preferences and interests;
9. Financial information such as, bank name and account details;
10. Income details;
11. IP address;
12. Cookies and tracker information from your browser and/or device;
13. Web browser type and version;
14. Operating system;
15. A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
16. Where you contact us by phone, email or post a record of that contact;
17. Where you contact us by phone we will retain a recording of that call. We do not place cookies on your computer or device, nor do We use any other means of data collection.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Regulations at all times. For more details on security see section 8 below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests (see section 7 below for further information). Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 For monitoring of calls made to and from customers to ensure that we are meeting the standards that we set;
6.2.6 Personalizing and tailoring Our services for you;
6.2.7 Replying to emails from you;
6.2.8 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing us on [enter appropriate email address]
6.2.9 Market research;
6.2.10 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.2.11 To manage your marketing preferences;
6.2.12 To manage your data processing preferences;
6.2.13 To compile anonymised data for analytical purposes.
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, and post with information, news and offers on our products and/or services., we will take all reasonable steps to ensure that we fully protect your rights and comply with Our obligations under the Data Protection Regulations (as may be updated from time to time).
6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.6.1 As a general rule, unless we have been requested to delete Your information, Customer personal data will be kept for the duration of the provision of the services and for a period of up to six years after the services have been terminated by You or Us. This is based upon the Limitation Act 1980 for the period in which someone can bring a breach of contract claim;
6.6.2 Where we have not provided You with any products or services (i.e. there has been no contract between You and Us), then we will keep your data for a period of 12 months.
6.6.3 We may keep data longer than stated in 6.6.1 and 6.6.2 where we are required to do so by law or a contractual obligation, however where we can we will anonymise such data so that it no longer identifies a living individual.
6.6.4 Call recordings are retained for a period of five years from the date that the call is made.
7. Legitimate Interest
7.1 Where we use legitimate interest for the basis of our processing of your personal data we shall ensure that we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual.
7.2 You have the right to object to our use of your personal data where we use legitimate interest as the basis of processing. You can do this by contacting us on the details in section 15.
7.3 Our legitimate interests include:
- The maintenance of our IT/Data Security systems and processes;
- Putting in place fraud prevention mechanisms;
- Keeping our records up to date;
- Working out which of our products and services may interest you and telling you about them (i.e. direct marketing);
- Developing products and services;
- Being efficient about how we fulfil our legal duties;
- Maintaining a marketing suppression list; and
- Complying with laws/regulations that apply to us.
8. How and Where Do We Store Your Data?
8.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
8.2 All our customer data is sorted and accessed from our servers in the UK / European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein) / Other.
8.3 However, some or all of your data may be stored/transferred outside of the UK. You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the UK, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and in compliance with the Data Protection Regulations including:
8.3.1 Carrying out due diligence on prospective parties to which we wish to transfer the data to;
8.3.2 Carrying out a risk assessment on the country to which we will transfer data to ensure that the protection offered to data subjects is equivalent to those provided in the UK, or accepted by the UK regulator as having adequate levels of protections (i.e. an adequacy decision exists);
8.3.3 Having in place written contracts on the transfer and use of the data (or using model contract clauses) that set out clearly the responsibilities of each party and the rights of data subjects;
8.3.4 Transferring data in an encrypted form or using a secure file transfer protocol;
8.3.4 Limiting the data transfer to only data that needs to be transferred to achieve the purpose.
9. Do We Share Your Data?
9.1 We may share your data with other companies for carrying out/putting in place the debt solution that we recommend and for reporting purposes. Money Bubble will conduct an assessment and get the customer’s permission to pass them to a licensed debt management or insolvency provider to setup/run their solution for them.
9.2 We may sometimes contract with third parties to supply services to you on Our behalf. These may include search engine facilities, advertising and marketing companies. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
9.3 In order to provide you with our services (and comply with our contractual obligations) we may need to share some or all of your personal data with our service providers:
- [Pebble protection LTF – FCA authorised Principal Firm]
- [Insolvency Practitioners]
- [Hubsolv CRM system]
- [Microsoft – Postal mailing services]
- [Outlook – Emailing platform for sending email communications]
- [Go Daddy – Hosting and server provider]
- [Hubsove CRM System – Campaign management platform]
- [www.moneybubble.co.uk – Customer feedback and reviews platform]
- [PDP Consultancy Services Ltd – Compliance consultant]
9.4 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
9.5 We may sometimes use third party data processors that are located outside of the UK. Where We transfer any personal data outside the UK, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Regulations including:
9.5.1 Carrying out due diligence on prospective parties to which we wish to transfer the data to;
9.5.2 Having in place written contracts on the transfer and use of the data (or using model contract clauses) that set out clearly the responsibilities of each party and the rights of data subjects; and/or;
9.5.3Transferring data in an encrypted form or using a secure file transfer protocol;
9.5.4 Limiting the scope of the data transfer to a ‘need to know basis’s only.
9.6 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9.7 We may share your data with regulators and disputes resolution bodies such as:
- The Financial Conduct Authority;
- The Information Commissioner Office;
- The Financial Ombudsman Service;
- Advertising Standards Authority; and
- Local Trading Standards
10. What Happens If Our Business Changes Hands?
10.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
11. How Can You Control Your Data?
11.1 In addition to your rights under the Data Protection Regulations, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you control on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Your Right to Withhold Information
12.1 You may access Our Site without providing any data at all.
13. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the Data Protection Regulations, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com or using the contact details below in section 15.
Date last updated: 24/03/2021
15. Contacting Us
If you would like to contact us, please contact Us at firstname.lastname@example.org, by telephone on 0161 768 0825, or by post at Money Bubble Ltd. 1 City Approach, Albert Street, Eccles Manchester, United Kingdom M30 0BL Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 13 above).