This privacy policy tells you what to expect us to do with your personal information and your privacy rights.
Contact details
Life Angel Ltd (Company Number 16760003)
Telephone: 0121 8161679
Email: lisa@lifeangelltd.co.uk
Life Angel Ltd is a data controller. Any reference to “we”, “us”, “our” or “ours” refers to Life Angel Ltd. Any reference to “you”, “yours”, “their”, or “theirs” refers to the client.
What information we collect, use, and why
We may collect or use the following information to provide and improve products and services for clients:
· Names and contact details
· Addresses
· Gender
· Occupation
· Date of birth
· Marital status
· Third party information (such as family members or other relevant parties)
· Financial and Transaction data (including details about payments to and from you and details of products and services you have purchased)
· Usage data (including information about how you interact with and use our website, products and services)
· Information relating to compliments or complaints
· Records of meetings and decisions
· Account access information
· Website user information
We also collect or use the following special category information to provide and improve products and services for clients. This information is subject to additional protection due to its sensitive nature and we will seek explicit consent from you before collecting and using this information:
· Race and ethnicity
· Religious or philosophical beliefs
· Sex life
· Sexual orientation
· Political opinions
· Trade union membership
· Health data
· Genetic data
· Biometric data
This information will only be collected if we require it to carry out a specific service you have requested. You may decline to provide this information, however this may affect the services we are able to provide to you.
We collect or use the following personal information for the operation of client or customer accounts:
· Names and contact details
· Addresses
· Purchase or service history
· Account information, including registration details
· Information used for security purposes
· Marketing preferences
· Technical data, including information about browser and operating systems
We collect or use the following personal information for information updates or marketing purposes:
· Names and contact details
· Addresses
· Profile information
· Marketing preferences
· Purchase or account history
· Website and app user journey information
· IP addresses
We collect or use the following personal information to comply with legal requirements:
· Name
· Contact information
· Identification documents
· Client account information
· Any other personal information required to comply with legal obligations
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Addresses
· Payment details
· Account information
· Purchase or service history
· Witness statements and contact details
· Relevant information from previous investigations
· Customer or client accounts and records
· Correspondence
· Location data
We also collect or use the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
· Race and ethnicity
· Religious or philosophical beliefs
· Sex life
· Sexual orientation
· Political opinions
· Trade union membership
· Health data
· Genetic data
· Biometric data
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
Your right to erasure - You have the right to ask us to delete your personal information.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
Your right to object to processing - You have the right to object to the processing of your personal data.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.
If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· In order for us to provide the services requested by our clients, we need to collect personal data relevant to the task required by them. If a client does not wish to provide their personal data, they can decline, however please be advised that this may reduce the services we are able to provide.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· Clients will be required to provide personal data to enable the setup and management of their client account. Clients may be required to upload documents to the secure portal to allow us to carry out services required by them. You may decline to provide personal data to us, however this may affect the services we are able to provide to you.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to comply with legal requirements:
· Processing is necessary for compliance with a legal obligation to which we are subject to.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· In order for us to handle queries and complaints effectively and in a timely manner, we will use personal data to identify clients, the services we have provided to them and a record of the personal information they have provided to us. This data will be held in accordance with data protection regulations.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
· Directly from you
· Automated technologies or interactions
· Publicly available sources
· Suppliers and service providers, which may include providers based outside of the UK
How long we keep information
We will only retain your personal data for as long as is necessary to fulfil the purposes that we collected it for. This includes for the purposes of satisfying any legal, accounting or reporting obligations we may have. We are legally required to retain basic information relating to our clients for six years after they cease being clients for tax purposes.
To assign an appropriate retention period that is applicable to the data, we will consider the amount, nature and sensitivity of the personal data, the purposes for which we collect and process the data, and if it is possible to achieve this via other means. We will also consider the applicable legal requirements associated with the data. In some instances, we will anonymise your personal data, so that it is no longer associated with you. This will be for research or statistical purposes, therefore we may use this data indefinitely, without further notice to you. You are permitted to request erasure of your data, in line with your data protection rights.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
External Third Parties:
· Sub-contractors that we use specifically to perform services provided to you
· Service providers that provide IT services, accounting software, data storage and mailing facilities
· Professional advisers based in the UK (banking, legal, insurance, accounting and consultancy services)
· Regulators, HMRC and other authorities based in the UK
Sharing information outside the UK
Some of our external third parties are based outside of the UK and therefore, where necessary, we may transfer your personal information outside of the UK. When doing so, we will only transfer your data to countries where an adequate level of protection for personal data is in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Security Measures
We have adopted appropriate security measures to ensure that your personal data is sufficiently protected against accidental loss, unauthorised access and usage, alteration or disclosure. Access to personal data is granted only to employees, agents, contractors or third parties that require the information for business purposes and data will only be processed on our instructions.
Cookies
Please read this carefully before using our website.
Cookies are simple text files that are stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, website’s domain name, and some digits and numbers.
We use the following types of cookies:
Necessary cookies - Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our website and using its features. For example, these cookies let us recognise that you have created an account and have logged into that account.
Functionality cookies - Functionality cookies let us operate the site in accordance with the choices you make. For example, we will recognise your username and remember how you customised the site during future visits.
Analytical cookies - These cookies enable us and third-party services to collect aggregated data for statistical purposes on how our visitors use the website. These cookies do not contain personal information such as names and email addresses and are used to help us improve your user experience of the website.
You will be provided with the option to accept or decline cookies when visiting our website. If you want to restrict or block the cookies that are set by our website, you can do so through your browser setting. Alternatively, you can visit www.internetcookies.com, which contains comprehensive information on how to do this on a wide variety of browsers and devices. You will find general information about cookies and details on how to delete cookies from your device.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113