Updated: 20 January 2020
The data controller is WDPUK Limited (referred to in this policy as “we”, “us” or “our”). We want you to be confident that the personal information you give us is safe and secure with us, and understand how we use it to offer you a better and more personalised experience on our Site.
The main purposes we collect and process your personal information are to: show you relevant content and to improve your experience on the Site; provide the services you sign up for, such as our deals services; communicate with you directly when you have consented, or when the law allows us to do this. Where we are processing your personal information in relation to our content and/or services, for the purposes of data protection legislation, we are controller of your personal information.
To operate the Life tools on our Site we may sometimes need to share your personal information with third parties. They will be responsible for how they process your personal information.
- When you register for Kai Money’s email you must provide us with your email address
- When you register to use our personalised tools, and any other personalised tools that we may launch from time to time that we operate, you may provide us with:
- Your personal details, including without limitation your name, postal and billing addresses, email addresses, phone numbers, date of birth, title, marital status, dependants, employment status, income and primary bank
- When you register for certain products via forms on our Site you may provide us with:
- Your personal details, including your email address, name and postal address
This section explains how we collect and use your personal information.
3.1. Kai Money Tips email
We collect your email address when you register to receive Kai Money Money Tips email. We use this to send you Kai Money Tips email. This is usually weekly, but on occasion we may send a special edition when we have something really important to share with you and it doesn’t happen very often.
3.2 Product Application Forms
We collect your personal information from you when you request certain products via forms on our Site. We use this so that we can manage your request. If we need to pass your personal information to a third party to meet your request, we will make it clear at the time you submit your details. In accordance with section 1 above, we recommend that you read the privacy policies of those third parties.
3.3. Personalised Tools
We need to collect certain personal information from you in order for you to interact with the Personalised Tools. We use this personal information to provide the services you’ve asked for.
3.4. Internal reporting, insight and analysis
3.5. Site Personalisation
We may use your personal information to personalise aspects of our Site, enable your details to be moved across our tools to speed up form filling and for market research. As part of this, we may match your personal information against information that has been collected by a third party. We are always working to make a better Site for you and using your personal information in this way helps us to do this. It also means that if you’ve given us permission, any email we send to you is appropriate for your needs.
3.6. Contacting you
We collect and may use your personal information to:
3.6.1 contact you in response to the communications that you have directed at us. We want to be able to help you so we use personal data to provide clarification or assistance in response to your communications;
3.6.2 invite you to take part in polls and other market research activities carried out by us and by other organisations on our behalf. Any feedback you provide will only be used to improve our Site and will not be published. However, if we contact you about this, you do not have to take part in the activities;
3.6.3 award you a prize if you have won a competition we’re running.
We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law (see section 12 below).
We will only collect and use your personal information (as described in sections 2 and 3) in accordance with data protection laws. Our grounds for processing your personal information are as follows:
- Consent – Where necessary we will only collect and process your personal information if you have consented for us to do so.
- Legitimate Interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of “legitimate interests” as a justification for processing your personal information. Our legitimate interests for processing your personal information are:
- to enable you to access and use the Site;
- to communicate with you about your use of the Personalised Tools. For example, sending you a confirmation email of your search results after you have used the Personalised Tools. Unless you have agreed, this won’t include communications about consumer news, other Personalised Tools, other Life tips, products and exclusives which we think you may be interested in; and
- to improve our Site. We may use your personal information to undertake demographic segmentation and generate profiling information to help us understand what you might be interested in and for market research. We are always working to make a better Site for you and using your personal information in this way helps us to do this.
You have a right to object to our use of your personal information for these legitimate interests, including a right to object to profiling by us.
The personal information that we collect when you use our Site is confidential. We may disclose your personal information to a third party in the following circumstances:
5.1. Our service providers – for the purposes described in sections 3.4 to 3.6 and 6 above, and for the purposes of providing certain services and enabling your interaction with the Site, such as your use of Personalised Tools. These include:
Our technical partners will not be permitted to use your personal information for their own marketing purposes unless you have consented to receive marketing from them on another site, as we won’t ask for your permission to do this on our Site.
5.3. If required to do so by any court, the Financial Conduct Authority or any other applicable regulatory, compliance, governmental or law enforcement agency;
5.4. If necessary in connection with legal proceedings or potential legal proceedings;
5.6. In line with our own Terms and Conditions.
Your privacy is of huge importance to us. All emails or other forms of communication directly from us to you will include clear instructions on how to unsubscribe. Plus, if you don’t want to be contacted by us anymore you can email email@example.com.
6.1. You have certain rights in relation to the personal information we hold on you:
6.1.1. Right to access: the right to a copy of the personal information we hold about you. Where you use the Personalised Tools we’ll ask you to describe the information you require, as well as letting us know about any other email addresses you’ve used on our Site, to enable us to trace your personal information. Depending on the nature of your request, we may also ask you for your full name, your date of birth and your full address and documents to allow us to verify your identity. Requests for copies of your personal information will be dealt with within one month, unless your request is complicated or if you have made a large number of requests. In these circumstances it may take us longer to deal with your request, in which case we will let you know if we need longer than one month to respond;
6.1.2. Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete. Requests for us to correct your personal information will be dealt with within one month, unless your request is complicated or if you have made a large number of requests. In these circumstances it may take us longer to deal with your request, in which case we will let you know if we need longer than one month to respond. If we believe that your personal data is accurate, we will let you know that we will not be amending your personal information and why;
6.1.3. Right to erasure and to restrict our use of your information: the right to request that we delete or remove your personal information from our systems. Data protection laws give exceptions to this right which, if applicable, we will explain in our response to you;
6.1.4. Right to restrict our use of your information: in some circumstances you can ‘block’ us from using your personal information or limit the way in which we can use it;
6.1.5. Right to data portability: the right to request that we move, copy or transfer your personal information;
6.1.6. Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests, or where we use your personal information to carry out profiling to inform our market research and user demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we’re continuing to process your personal information. Some of the Personalised Tools give you the option to hear from us by email about tips, news, and relevant Life products and exclusives. You have the right to object to our processing of your personal information in this way;
6.1.7. Withdrawal of consent: where you have provided us with consent to use your personal information, you can withdraw this at any time;
We will use reasonable efforts consistent with our legal duty to provide you with your rights in accordance with data protection legislation.
9.3. If you’re not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator. In the UK, this is the Information Commissioner’s Office.
7.1. Keeping information about you secure is very important to us so we store and process your personal information in accordance with the high standards required under data protection legislation. From time to time and for operational reasons the personal information we collect from you may be transferred to and stored in countries outside of the European Economic Area (“EEA“). Your information may also be processed by some of our service providers which operate outside the EEA. Different countries have different data protection and security laws and some of these do not offer the same level of protection as you enjoy under UK data protection legislation. However, when we appoint our service providers to help us provide products and services to you (which may include some based in the USA), we take care to ensure that we have put in place contractual protections, for example European Commission-approved contractual clauses, and that our service providers have appropriate security measures in place.
We do our best to keep the information you disclose to us secure. However, we can’t guarantee its security. By using our Site you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.
Effective as of: 20 January 2020