Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Information. It also explains your rights in relation to your Personal Information and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain Personal Information about you. When we do so we are subject to data protection laws applicable in the United Kingdom and we are responsible as ‘controller’ of that Personal Information for the purposes of those laws.
1. KEY TERMS It would be helpful to start by explaining some key terms used in this policy:
We, us, our : Casieblue.co.uk a trading name of Casieblue Group Limited, a company registered in England and Wales with registered address 3rd Floor, 86 - 90 Paul Street London United Kingdom EC2A 4NE
Personal Information: Any information relating to an identified or identifiable individual
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU
The information we collect about you and how we use it may vary depending on the products and/ or services we can or currently provide to you. We may collect and use the following Personal Information about you for example:
• your name, address, date of birth, and contact information, including email address and telephone number;
• your credit or debit card information, information about your bank account and other banking information;
• your contact with us, such as a note or recording of a call you make to one of our contact centres, an email or letter sent, or other records of any contact with us;
• your account information, such as dates of payment owed or received, account numbers or other information related to your account;
• your employment details; and
• information about how you use our website. This Personal Information is required to inform you about the products and/or services we can or currently provide to you. Where you fail to provide that Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products and/or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time
3. HOW YOUR PERSONAL INFORMATION IS COLLECTED
We collect most of this Personal Information directly from you, by telephone, text or email and/or via our website and apps. However, we may also collect information:
• from publicly accessible sources, e.g. social media websites;
• directly from a third party, e.g.: - sanctions screening providers; - credit reference agencies; - customer due diligence providers;
• from a third party with your consent, e.g. your bank or building society; and
• from cookies on our website. For more information on our use of cookies, please see our cookies policy published on the legal page of our website.
4. HOW AND WHY WE USE YOUR PERSONAL INFORMATION
Under data protection law, we can only use your Personal Information if we have a proper reason for doing so. In order to use your personal information, we rely on the following legal bases:
(i) processing is necessary for the performance of the products and/or services we provide to you;
(ii) processing is necessary for the purposes of the legitimate business interests pursued by us (including, for example, improving products and/or services that we offer); and
(iii) processing is necessary for compliance with a legal obligation to which we are subject (including where applicable undertaking customer due diligence checks for Anti-money Laundering, Fraud and Sanctions purposes);
(iv) processing is necessary for compliance with a legal obligation to perform a specific task in the public interest (including for example, assisting with detecting and preventing fraud, tax evasion and financial crime, or to safeguard the interests of vulnerable customers.
Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (see ‘How to contact us’ below). We collect and process your personal information in order to:
• provide products and/or services to you;
• update customer records;
• prevent unauthorised access and modification to our systems; and
• undertake statistical analysis to help us manage our business e.g. in relation to financial performance, client base and work type.
5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We routinely share Personal Information with:
• companies within the Casieblue Group Limited;
• third parties we use to help deliver our products and/or services to you;
• other third parties we use to help us run our business, eg marketing agencies or website hosts;
• third parties approved by you;
• credit reference agencies; and
• our insurers, brokers and other professional advisers. We only allow our service providers to handle your Personal Information if we are satisfied they take appropriate security measures to protect your Personal Information.
We may be obliged to disclose and/or exchange information with law enforcement agencies and regulatory bodies, or another third party where such disclosure is required to comply with our legal and regulatory obligations. We will make information available if it is deemed reasonable for the purposes of protecting ourselves or our customers against fraud. We may also need to share some Personal Information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
6. CREDIT REFERENCE AGENCIES
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). To do this, we will supply your Personal Information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information. We will use this information to:
• assess your creditworthiness and whether you can afford to take the product;
• verify the accuracy of the data you have provided to us;
• prevent criminal activity, fraud and money laundering; • manage your account(s);
• trace and recover debts; and
• ensure any offers provided to you are appropriate to your circumstances. We will continue to exchange information about you with CRAs while you have a relationship with us.
We will also inform the CRAs about your account and share appropriate information with them. If you do not pay in full and on time or if you otherwise breach the agreement that we have with you, CRAs will record this information. This information may be supplied to other organisations by CRAs. When CRAs receive a search from us they will place a search footprint on your credit file that will be seen by other lenders. If you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link. The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at:
Equifax www.equifax.co.uk/crain
https://www.equifax.co.uk/About-us/Privacy_policy.html
TransUnion https://www.transunion.co.uk/crain
http://www.TransUnion.co.uk/legal-information/bureau-privacy-notice
Experian https://www.experian.co.uk/crain
https://experian.co.uk/consumer/privacy.html
7. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Any personal data that we have collected and processed about you will be retained in accordance with the retention periods set out in Casiebluewater’s data retention schedule.
To determine the appropriate retention period for your Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements. When it is no longer necessary to retain your Personal Information, we will anonymise it and either delete it, or put it beyond use where it is not technically possible to delete it.
Even if you don’t sign up with Casieblue Store, we will continue to hold personal information about you to enable us to comply with our legal and regulatory obligations, and to assist us in the prevention and detection of fraud.
8. TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE UK
We may transfer Personal Information that we collect from you to third party data processors, vendors or hosting partners acting on our behalf located in countries outside of the UK, such as the US and European Economic Area (“EEA”), or to other entities in our group of companies in connection with the purposes set out above. Where this is the case, Casieblue Group Limited and its trading name will put in place adequate safeguards (by way of standard contractual clauses) in order to protect your personal data in accordance with the applicable data protection legislation. If you would like further information please contact us (see ‘How to contact us’ below).
9. YOUR RIGHTS
You have the following rights, which you can exercise free of charge:
Access: The right to be provided with a copy of your Personal Information (the right of access).
Rectification: The right to require us to correct any mistakes in your Personal Information.
Erasure: The right to require us to delete your Personal Information – in certain situations. For legal reasons we are not always able to do so. There may be times when we continue to use your personal data when we say it’s in our ‘legitimate interest’.
Restriction of processing: The right to require us to restrict processing of your Personal Information – in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability: The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.
To object: The right to object: – at any time to your Personal Information being processed for direct marketing (including profiling); or – in certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Withdraw consent : The right to withdraw your consent to us processing your Personal Information at any time if our processing is based on your consent.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
• email, call or write to us – see below: ‘How to contact us’; and
• let us have enough information to identify you (eg your full name, address and customer or matter reference number);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.
10. KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent Personal Information from being accidentally lost, destroyed, used or accessed unlawfully. These measures are reviewed on an ongoing basis.
We make every effort to ensure your Personal Information is protected and have robust procedures in place to deal with any data breach. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
We will never ask you for personal information or account information by an unsolicited means of communication.
If you are in any doubt, please use the online chat function on the Casieblue Store website or telephone: 02032906063.
11. RIGHT TO COMPLAIN
We hope that we can resolve any query or concern you may raise about how we use your information. Please email us at info@rcasiemobile.co.uk and we will endeavour to resolve the compliant promptly.
If you are still not satisfied, you also have the right to lodge a complaint with the UK Supervisory Authority, Information Commissioners Office (ICO) who may be contact at https://ico.org.uk/concerns or telephone: 02032906063
For more information, please visit their website, www.ico.org.uk.
12. CHANGES TO THIS PRIVACY POLICY
We may update this policy for example, where a change to the regulation requires us to do so.
Whenever we make a change, we will post this on our website and let you know if there is a material change.
We encourage you to check our website from time to time to keep informed of any changes.
The privacy policy and cookies policy were last updated June 2021.
13. HOW TO CONTACT US
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information, we hold about you. Our contact details are shown below:
Our Contact Details:
Casieblue Store
Trading name of Casieblue Group Limited
3rd Floor, 86 - 90 Paul Street
London
EC2A 4NE