Website Privacy Policy
Introduction
Welcome to The Employee Benefits Corporation’s (EBC) website Privacy Policy.
EBC respects your privacy and is committed to protecting your personal data. This Privacy Policy 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 tell you about your privacy rights and how the law protects you.
Purpose of this Website Privacy Policy
This Privacy Policy aims to give you information on how EBC collects and processes your personal data through your use of this website, including any data you may provide through this website when you submit a request via the ‘Contact Us’ facility on our website.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide 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 Privacy Policy supplements the other notices and is not intended to override them.
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please use the contact the details set out below.
Data Protection, The Employee Benefits Corporation Ltd, Unit 1 The Hub,14 Station Road, Henley on Thames, Oxon, RG9 1AY.
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. 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 privacy policy and your duty to inform us of changes
We may update this Privacy Policy from time to time, you should check our website periodically to ensure you have the latest version.
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.
Third-party links
This website may include links to third-party and EBC group company websites. Clicking on those links 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 privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We only collect limited personal data from our website. For example, EBC products and services cannot be applied for or opened via our website. So we only obtain personal data which you, or those acting on your behalf, may submit to us via the “Contact Us” facility.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share information showing how our websites are used however, this is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may use this information to calculate the percentage of users accessing a particular page or specific website feature and to analyse how we can improve our website functionality, products and services, customer relationships and experiences. This helps us to develop our business and inform our marketing strategy. Please see our Cookie Policy for further information about this and how we use third party analytics to assist us.
If you open an email from us we may automatically collect technical information including browser type, device type, whether an email was opened and/or unsubscribed from. This information does not constitute personal data.
We do not ask for any Special Categories of Personal Data about you via the website (this includes details about your race or ethnicity, religious 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.
How is your personal data collected?
When you use our website we use different methods to collect data from and about you including through:
You are entitled to browse our website without disclosing any personal information.
How we use your information
You will be informed of the way in which we will use your personal information before you submit it.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data from your use of the website for the following lawful purposes, to:
We may also use your data to administer, improve and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data. This would be for our legitimate interests (for running our business, provision of administration or IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring), or alternatively to comply with a legal obligation.
Marketing
You may receive marketing communications from us if you have specifically requested this from us or where we are otherwise legally entitled to do so, and, in each case, you 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 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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes explained above.
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.
We will never sell your personal data to a third party.
International transfers
We should not have to share your information with third parties outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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.
Email addresses: Where you have requested us to contact you we will communicate with you via email and/or telephone, depending on what you have specified. By doing so, you acknowledge that because of the nature of the internet the security of emails cannot be guaranteed.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. If you become a customer of EBC we will retain information about our customers for at least seven years after they cease being customers for legal and regulatory purposes.
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 requirements.
In some circumstances you can ask us to delete your data, see below for further information.
In some circumstances we may 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
If you wish to exercise any of the rights set out above, please use the contact details above.
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 unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
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