Privacy Policy
WEBSITE PRIVACY & COOKIE NOTICE
This privacy policy was last updated on 01 March 2023.
What does this notice cover?
This
Privacy Notice describes how Woolona will
make use of your data when you use our products, services and websites.
It
also describes your data protection rights, including a right to object to some
of the processing which Woolona carries out. More information about your
rights, and how to exercise them, is set out in the "What rights do I
have?" section.
We
may also provide you with additional information when we collect personal data,
where we feel it would be helpful to provide relevant and timely information.
What information do we collect?
- Your name, age, date of birth
and gender.
- Contact details, such as your
billing and shipping address, email address and phone number. Your user
name and password.
- Banking information, including
your debit or credit card information and sort code and account number and
also transactional information including in respect of products which you
purchase or when you apply for Woolona.
- Financing or another form of
financing we offer.
- Your personal preferences, such
as information about your household and purchase decisions.
- Information about your
communications with us.
- Your marketing preferences,
including any consents you have given us.
- Product reviews or testimonials
and other content you submit to us.
- Location data we get about
where you are, such as the address where you connect a computer to the
internet, or a shop where you buy something with your card.
- Information related to the
browser or device you use to access our website.
- Information about your website
preferences.
How do we use this information, and what is
the legal basis for this use?
We
use the personal data referred to above and information which you give us for
the following purposes:
To fulfil a contract, or take steps linked to a contract: this
is relevant where you apply for one of our financial products or services. This
includes:
- Taking and processing payments.
- Communicating with you and
providing customer services.
- Arranging the delivery or other
provision of products, services or prizes.
- Administering our loyalty
programs
- Managing our relationship with
you.
Where necessary for Woolona 's legitimate interests, as listed below, and where our
interests are not overridden by your data protection rights:
- Providing products and services
you have requested and responding to any comments or complaints you may
send us. We may process personal data about your dependents, family and
partner (which you give to us) in doing so.
- Facilitating the creation of,
and securing, online registered accounts.
- Promoting our services to
customers and potential customers, advising you of news and updates, and
hosting or administering events.
- Monitoring the use of our
websites and online services and using your information to help us
monitor, improve and protect our products, content, services and websites,
both online and offline.
- Personalizing our website,
products or services for you.
- Investigating any complaints
received from you or from others, about our services, products or
websites.
- To run our business in an
efficient and proper way. This includes managing our financial position,
business capability, planning, communications, corporate governance and
audit.
- Monitoring customer accounts to
detect, prevent, investigate and/or report fraud, terrorism,
misrepresentation, security incidents or crime in accordance with
applicable law.
- Managing how we work with other
companies that provide services to us and our customers.
- In connection with legal claims
and for compliance, regulatory and investigative purposes.
- Call recordings when you call
our call center (we will always flag to you when a call is being
recorded).
- Applications which you give us
if you are applying for a job or information that we obtain from referees
or your previous employers.
- To assist us in evaluating and
improving the quality of the products and services we supply
- Collecting Internet Protocol
(IP) addresses during the creation of an order to prevent fraud.
Where you give us consent:
- We will send you direct
marketing by email and/or SMS in relation to our products and services.
- We will place Cookies and use
similar technologies in accordance with our Cookies Policy (below) and the
information provided to you when those technologies are used.
- On other occasions where we ask
you for consent, we will use the data for the purpose which we explain at
that time.
For purposes which are required by law:
- Undertaking checks on
customers, potential customers and other third parties for the purpose of
compliance with our legal, regulatory and professional obligations.
- In response to requests by
government or law enforcement authorities conducting an investigation.
- We have carried out balancing
tests for all the data processing we carry out on the basis of our
legitimate interests, which we have described above. You can obtain
information on any of our balancing tests by contacting us using the
details set out below.
- We will not be able to provide
the products or other services requested if we are not provided with all
relevant personal data. The provision of some information, such as the
details you provide so we can send you marketing communications, is optional.
Automated decision making
In
performing some of the functions above, we rely on technology that makes
automatic decisions based on the criteria we determine to be relevant and the
information we collect about you or a particular transaction. These include
credit and fraud checks. We routinely test our software to improve the accuracy
of these decisions and to prevent unintended bias. These decisions can have
significant effects for you, such as:
- Preventing access to our
services, where we determine there
is a high likelihood that providing the service to you would cause us to
violate our regulatory requirements.
- Cancelling transactions, where we determine there is a high likelihood
that a transaction is fraudulent (for example, because the payment is made
from a location that does not correspond to our records for that
end-customer) or the payer does not have sufficient funds to cover the
expense.
- Cancelling the service, where we determine that the service is being used
in violation of our terms. For example, we automatically analyze your
transactions to assess whether any of the activities you conduct appear on
our list of restricted activities.
Who will we share this data with?
We
will share your personal data with other members of the Woolona to administer
and manage group functions, including the provision of our products and
services to you.
Your
personal data will also be shared with trusted third parties, such as financial
or other advisers, consultants and other professional experts.
We
will share your personal data with companies providing services under contract
to Woolona. Such third parties include providers of order fulfilment services,
website and IT hosting, help desks, maintenance, call center operations,
marketing research and analysis, credit card payments and customer feedback
platforms.
Your
personal data will also be shared with government agencies and/or law
enforcement agencies and credit reference and fraud prevention agencies if
required for the purposes above, if mandated by law or if required for the
legal protection of our legitimate interests in compliance with applicable
laws.
In
the event that the business is sold or integrated with another business, your
details will be disclosed to our advisers and any prospective purchaser’s
adviser and will be passed to the new owners of the business.
What rights do I have?
You
may be entitled to ask Woolona for a copy of your personal data, to correct,
delete or restrict processing of it, and to obtain the personal data you
provide in a structured, machine readable format and ask us to share (port)
this personal data to other organizations. You may also have the right to
object to processing in some circumstances.
Where
we have asked for your consent, you may withdraw consent at any time. If you
ask to withdraw your consent to Woolona processing your personal data, this
will not affect any processing which has already taken place at that time. You
can also ask us not to send or to carry out profiling for direct marketing, at
any time.
These
rights may be limited, for example if fulfilling your request would reveal
personal data about another person, where they would infringe the rights of a
third party (including our rights) or if you ask us to delete information which
we are required by law to keep or have compelling legitimate interests in
keeping. Relevant exemptions are included in both the GDPR and in the Data
Protection Act 2018. We will inform you of relevant exemptions we rely upon
when responding to any request you make.
If
you wish to exercise these rights, please contact us.
If
you have unresolved concerns you have the right to complain to an Unites States
data protection authority where you live, work or where you believe a breach
may have occurred.
Cookie Policy
What are Cookies and similar technologies?
Cookies
are small pieces of information sent by a web server to a web browser which
allows the server to uniquely identify the browser on each page. Other tracking
technologies are also used which are similar to Cookies. This can include pixel
tags and tracking URLs. All these technologies are together referred to in this
policy as "Cookies".
How do we use Cookies?
The
types of Cookies that we use on our website, and the purposes for which they
are used, are set out below:
- Strictly necessary Cookies: These Cookies are essential in order to enable
you to move around our website and use its features, such as accessing
secure areas of our site. Without these Cookies, any services on our
website you wish to access cannot be provided.
- Analytical/performance Cookies: These Cookies collect information about how you
and other visitors use our site, for instance which pages you go to most
often, and if you get error messages from web pages. We use data from
these Cookies to help test designs and to ensure a consistent look and
feel is maintained on your visit to the website. All information these
Cookies collect is aggregated. It is only used to improve how a website
works.
- We use Google Analytics, for example, to anonymously track website usage and
activity. Google Analytics is a web analytics service provided by Google,
Inc. (“Google”). Google Analytics uses “Cookies”, which are text files
placed on your computer, to help the website analyze how users use the
site. The information generated by the Cookie about your use of the
website (including your IP address) will be transmitted to and stored by
Google on servers in the United States. In case of activation of the IP
anonymization, Google will truncate/anonymize the last octet of the IP
address for Member States of the European Union as well as for other
parties to the Agreement on the European Economic Area. Only in
exceptional cases, the full IP address is sent to and shortened by Google
servers in the USA. On behalf of the website provider Google will use this
information for the purpose of evaluating your use of the website,
compiling reports on website activity for website operators and providing
other services relating to website activity and internet usage to the
website provider. Google will not associate your IP address with any other
data held by Google. You may refuse the use of Cookies by selecting the
appropriate settings on your browser. However, please note that if you do
this, you may not be able to use the full functionality of this website.
Furthermore you can prevent Google’s collection and use of data (Cookies
and IP address) by downloading and installing the browser plug-in
available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
- You can refuse the use of
Google Analytics by clicking on the following link. An opt-out Cookie will
be set on the computer, which prevents the future collection of your data
when visiting this website:
- Disable Google Analytics
- Further information concerning
the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.html or at https://www.google.de/intl/en_uk/policies/. Please note that on this website, Google Analytics
code is supplemented by “anonymizeIp” to ensure an anonymized collection
of IP addresses (so called IP-masking).
- Functional Cookies: These Cookies allow our site to remember choices
you make (such as your user name, language or the region you are in) and
provide enhanced, more personal features. These Cookies can also be used
to remember changes you have made to text size, fonts and other parts of
web pages that you can customize. They may also be used to provide
services you have asked for such as watching a video or commenting.
Additionally, these Cookies can be used to allow an optional service to
function such as offering a live chat session. The information these
Cookies collect may be anonymized and they cannot track your browsing
activity on other websites.
- Targeting Cookies: These Cookies are used to deliver adverts more
relevant to you and your interests. They are also used to limit the number
of times you see an advertisement as well as help measure the
effectiveness of the advertising campaign. These Cookies are dropped only
with your consent. You can give your consent either by closing the Cookie
banner displayed on the landing page of our website or browsing the
website outside the Cookie banner and clicking on any of its item. Please
note that we track your consent using a technical Cookie; therefore, in
the event you delete any Cookies stored on your devices you see the Cookie
banner once again. They are usually placed by advertising networks with
the website operator’s permission. They remember that you have visited a
website and this information is shared with other organizations such as
advertisers. Quite often targeting or advertising Cookies will be linked
to site functionality provided by the other organization.
- Social media Cookies: These Cookies allow you to share what you’ve been
doing on our Site on social media such as Facebook and Twitter. These
Cookies are not within our control. Please refer to the respective privacy
policies for how their Cookies work.
- Pixel tags: Also known as a clear GIF or web beacon. These
are invisible tags placed on certain pages of our Site but not on your
computer. When you access these pages, pixel tags generate a generic
notice of that visit. They usually work in conjunction with Cookies,
registering when a particular device visits a particular page. If you turn
off Cookies, the pixel tag will simply detect an anonymous website visit.
- Tracking URLs: These are used to determine from which referring
website the website is accessed.
- FullStory collects information on your use of the Site,
such as pages visited, links clicked, mouse movements, as well as
information more commonly collected such as the referring URL, browser,
operating system, and Internet Protocol (“IP”) address. Fullstory use
publicly available sources to approximate your geographic region and
Internet Service Provider based on your IP address. FullStory’s purpose in
collecting this data is to better understand how you use the Site. If you
want more details on FullStory please see their privacy policy https://www.fullstory.com/legal/privacy/
- If you wish to opt out of
FullStory collecting information please click the link https://www.fullstory.com/optout/
- Opting out will create a Cookie
that tells FullStory to turn off recording on any site which uses the
FullStory Services. The presence of this Cookie is required to continue
opting out. That means if you clear your browser Cookies, you will have to
opt-out again.
If
you do not want to allow Cookies at all, or only want to allow use of certain
Cookies, please refer to the Cookie Settings button at the bottom of the
website which allows you control over what groups of Cookies you allow. You can
also use your browser settings to withdraw your consent to our use of Cookies
at any time and delete Cookies that have already been set. Please note that by
deleting our Cookies or disabling future Cookies you may not be able to access
certain areas or features of our site.
To
find out more about Cookies please visit: http://www.allaboutCookies.org or see www.youronlinechoices.com which contains further information about
behavioral advertising and online privacy.
How long will you retain my data?
Where
we process account registration data, we do this for as long as your account is
active or you are an active user of our sites and for no more than six years
after this.
Where
we process personal data in connection with performing a contract or for a
competition or survey, we keep the data for six years from your last
interaction with us.
Where
we process personal data for marketing purposes or with your consent, we
process the data until you ask us to stop and for a short period after this (to
allow us to implement your requests). We also keep a record of the fact that
you have asked us not to send you direct marketing or to process your data so
that we can respect your request in future.
Updates to this Privacy Notice
This
Privacy Notice may be updated periodically. We will update the date at the top
of this Privacy Notice accordingly. On some occasions, we may also actively
advise you of specific data handling activities or significant changes to this
Privacy Notice as required by applicable law.