This Privacy & Cookies Policy (the “Policy”) has been prepared to meet the requirements of the UK’s Data Protection Act 1998 and The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011, (the “Acts”). It relates to the collection, protection, disclosure and use of personal data belonging to individuals who visit www.touchfinancial.co.uk (our “Site”) and also refers in detail to the “Cookies” we use, what they are and their purpose. By clicking the “OK” button on the box that appears on the first page you enter on our Site, you signify your acceptance of our Cookies Policy. If you wish subsequently to decline your acceptance of them we set out in Clause 4 of the Policy how you may do so. Please note that the box relating to “Cookies” will only appear the first time you enter our Site.
Your privacy and security is important to us. This Policy sets out how we will treat any personal information we obtain from you and it is intended to help you understand how we deal with it and how you may remove it. By providing your personal information to us, you agree that we may collect and use the personal information you provide in the ways described in this Policy. If you do not agree with the terms of this Policy, please do not provide any personal details to us.
We will use your personal information only for the purposes set out below.
Please note that we may need to update this Policy from time to time to reflect changes in the law. We recommend that you check this page regularly to ensure that you have read the most recent version and that you are happy with any changes.
This Policy was last revised on: 3 February 2015
1.1 It is your choice to provide us with personal information. We may provide you with the option to select whether you would like to receive information from us or from trusted third parties by opting in or out of receiving promotional offers.
1.2 Ways in which you may be providing us with personal information include, for example,
1.2.1 contacting us with an enquiry;
1.2.2 filling in a form; and/or
1.2.3 reporting a problem.
1.3 With regard to each of your visits to our Site we may automatically collect the following information:
1.3.1 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
1.3.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
1.4 The information we will collect from you includes, but is not limited to data concerning traffic on our Site, location data, weblogs and other communication data, and the resources that you access.
1.5 By providing any personal information to us, you fully understand and clearly consent to the transfer, collection and processing of such personal information. Such transfer, collection and processing will comply with the terms of this Policy.
2.1 Like many other websites, we use “cookies” to help us gather and store information about visitors to our Site.
2.2 We may collect information about your computer, including your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our Site users’ browsing actions and patterns, and does not identify you as an individual.
2.3 A “cookie” is a small text file which is downloaded on to your computer’s hard disk when you access certain websites. Cookies allow the website to recognise your computer. A cookie can identify the pages that are being viewed and this can assist us to select the pages that the visitor sees.
2.4 Some cookies, called “persistent” and which are not session-based, remain on a visitor’s computer, so that you can be recognised as a previous visitor when you next visit our Site. This allows us to collect information about your browsing habits whilst on our Site, and this can be useful in assisting us to monitor and improve our services.
2.5 We do not store sensitive information such as account numbers or passwords in “persistent” cookies, and cookies in themselves, do not contain enough information to identify you. You will only become personally identifiable in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined in Section 1.2 above.
2.6 In addition to using cookies, we might also use GIFs and other web tools, such as Google Analytics, to collect information about your browsing activities whilst on our Site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
2.7 Any information that we acquire about you using cookies, GIFs, or other web tools is subject to the same restrictions and conditions as any other information we collect about you, as outlined in this Policy.
3.1 Cookies set by our Site:
3.1.1 We use a few different cookies which enable our Site to improve your experience and help our marketing team assess what the users want and do not want.
3.1.2 Session cookies* – these cookies are temporary files, being wiped from your computer once the browser session is closed. If you come to our Site you may enter information. Without session cookies, you would have to re-enter this information every time you visit a new page which is very tedious.
3.1.3 Analytics cookies* – an extremely common phenomenon for sites now is to view site analytics. These are stats which show visitor numbers, visitor locations, bounce rates (how quickly the user clicks away from the site) and other user pathway analysis. However, without analytics cookies, gathering this data would become impossible and we would not be able to use the data to build upon user experience and identify what materials users enjoy viewing.
The analytics software we use is called Google Analytics.
*Note that these cookies do not save any of your personal information.
3.2 If you wish to know all the cookies we have set and how to delete or manage them, please refer to www.allaboutcookies.org.
4.1 You have the ability to accept or decline cookies by modifying the settings in your browser or by not clicking the “OK” button on the box that appears on the first page you see on our Site. However, you may not be able to use all the interactive features of our Site if the cookies are disabled.
4.2 You also have the ability to delete cookies that have been installed in the cookie folder of your browser and should search for “cookies” in your “Help” function for information on where to find your cookie folder.
5.1 All information you provide to us is stored on our secure servers.
5.2 The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA, who work for us or for one of our lenders. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
6.1 We may use personal information collected from you to provide specific services that you request and to provide additional services that may be of interest. We may use your personal information in the following ways:
6.1.1 Ease of Use – To ensure that content from our Site is presented in the most effective manner for you and for your computer.
6.1.2 Administration – To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
6.1.3 Communication – To notify you, by way of example, about changes to our service.
6.1.4 Marketing Communications and Analysis – To communicate with you about our services and for our own internal marketing analysis, for example, to measure the amount of traffic to our Site. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
7.1 If you are an existing customer, we will only contact you by email with information about services similar to those which were the subject of previous business with you.
7.2 If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you be electronic means only if you have consented to this.
7.3 If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please email us at firstname.lastname@example.org or write to us at Touch Financial Support Limited 9 Ensign House, Admirals Way Marsh Wall, London E14 9XQ.
7.4 Please note that we will not, under any circumstances, sell your personal information to anyone else.
7.5 Any information or statistics relating to our business that we disclose to others will not identify you personally. We may, for example, perform statistical analyses of the behaviour of the users of our Site in order to measure interest in the various areas and to inform advertisers as to how many consumers have “clicked” on their advertising banners. This information, and other general information about our users that we share with advertisers and other partners, will not contain personal information about you.
8.1 This Policy only covers this Site. If you follow a link from this Site to another website, you must refer to and read the privacy statement on that other website which you visit. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check their policies before you submit any personal data to these websites.
9.1 We may disclose your personal information:
9.1.1 to third parties to whom you have provided your consent in order that they will be able to prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you.
9.1.2 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer.
9.1.3 if Touch Financial Limited, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
9.1.4 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Website Use and other agreements; or to protect the rights, property, or safety of Touch Financial Support Limited, our lenders, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
10.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you, before collecting your data, if we intend to use your data for such purposes or if we intend to disclose your data to any third party for such purposes. You can exercise your right at any time to prevent such processing by emailing us at email@example.com or writing to us at Touch Financial Support Limited at 9 Ensign House, Admirals Way Marsh Wall, London E14 9XQ.
The Acts give you the right to access information we hold about you. Any access request will be subject to a fee of £10 to meet our costs in providing you with such information. If you would like a copy of this information, please write to us at the address below.
12.1 Questions, comments and requests regarding this Policy are welcomed and should be addressed to firstname.lastname@example.org or Touch Financial Support Limited at 9 Ensign House, Admirals Way Marsh Wall, London E14 9XQ.
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