A life Change

PRIVACY POLICY

THIS POLICY COVERS
A Life Change is a digital marketing company.

We work with over 150 High St brands, financial services, automotive, home improvement and lifestyle brands to provide you with personalised marketing content from these brands via email. Our aim is to provide you with offers and content that we believe may be relevant to you.

Your data will only be on our database if you have consented to sharing your data with A Life Change, one of its’ owned websites or mailing brands, or with third-party partners and marketing services providers

A Life Change is committed to transparency in terms of how we collect and use your "personal data".

"Personal data" is defined in Article 4(1) of the GDPR:

"(1) 'personal data’ means any information relating to an identified or identifiable natural person ('data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

That’s why we’ve developed this privacy and cookies policy ("Policy"), which:
  • sets out the types of personal data that we collect
  • explains how and why we collect and use your personal data
  • explains when and why we will share personal data within the A Life Change Group and with other organisations; and
  • explains the rights and choices you have when it comes to your personal data

A Life Change or one of its’ mailing brand (referred to in this policy as "A Life Change" or "us" or "we") is the Data Controller as defined by the Data Protection Act 2018.

HOW WE USE YOUR PERSONAL DATA
In this Section we have set out:
  1. the general categories of personal data that we may process;
  2. the purposes for which we may process personal data; and
  3. the legal bases of the processing.
WHAT DATA IS COLLECTED AND WHAT DO WE PROCESS

A Life Change collects both non-personal and personal data on an ongoing basis.

  1. Non-personal data
  2. Web browser details, operating system data, date and time stamps.
  3. Personal Data
  4. A Life Change collects 6 types of personal data
  • Internet Protocol (IP) addresses
  • Email address and consent data
  • Demographic data – such as age, gender, home and car ownership & insurance, salary bands and address
  • Behaviour data ("service data") – such as what you open, click on and transaction categories
  • Device data – the types of device you use – Desktop, phone and tablet data
  • Suppression data – This is where you have unsubscribed from us or a brand. We store this information to ensure we do not re-contact you in the future or from a brand you have chosen not to hear from.

In addition to the above, we may append pubically available data to your email address, postal addess or telephone number. For instance, we may match your postal address to data publically available through the Land Registry database.

We may process data about your use of the emails we send and visit to our website and services. ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, which emails you open and do not open, which emails you click on and do click on, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website, emails we send and services. The legal basis for this processing is legitimate interests, namely monitoring and improving our website, email sending strategy and services.

We may process your information attached to your email address, for example postcode or gender, "personal data". The profile data may include your name, address, email address, gender, date of birth, relationship status, interests and hobbies and employment details. The profile data may be processed for delivering you a better service by providing more relevant marketing and advertising offers. The legal basis for this processing is consent. Consent was obtained at the point the email was submitted on our partner websites. At any point you can opt-out by clicking here.

We may process your personal data that is provided in the course of the use of our services ("service data"). The service data may include a record of the types of offers you opened, clicked or transacted on. Information will be aggregated into verticals e.g. clicked on a retail offer. The source of the service data is your engagement with the emails we send. The service data may be processed for the providing our services and to communicate with you in a more effective and relevant manner. The legal basis for this processing is legitimate interest, namely the proper administration of our business.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is legitimate interest, namely the proper administration of our website and business and communications with users.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interest, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

WHY WE COLLECT PERSONAL DATA

We collect personal data so that we can target you with offers and content that we believe may be relevant to you. Without profiling you in this manner, we would send you less relevant marketing messages. Profiling may include basic information like your postcode and targeting you with local brands. It could be more detailed, such as your salary banding, so that we can send you relevant products for your income bracket. In general, profiles are grouped into segments to aid targeting rather than by individual targeting.

We do not use data for medical or religious purposes. We do not store data to identify sexual orientation, political beliefs or religious beliefs.

We do aggregate personal data to develop and improve the content we display to you on the website and send you via email. For example, as there is an increase in mobile usage, our design process has used data to understand device usage.

We do use personal data to detect fraudulent activity on our advertising campaigns. For example, this may include detecting invalid applications for a financial product, or detecting too many clicks from the same source.

We do use your personal data to pass your details onto a FCA approved insurance broker for insurance quotations, manage promotions and competitions you enter, to contact you or select you for a promotion.

HOW WE COLLECT PERSONAL DATA
We collect data in 3 ways
  • Data you enter by forms, either on our websites, partner websites or through an email we send.
  • Browsing data such as views, clicks and transaction history on websites we control
  • Open, click and transaction behaviour on emails we send.
When you register for our Services, you may provide us with:
  • Your personal details, including your postal addresses, email addresses, phone numbers, gender and date of birth, title plus home and car insurance information, newsletter preferences and marketing consents. Please note this list is not inclusive and you may provide us with other information.
When you visit our Websites, or open an email from us:
  • Data about your online purchases (for example, what you have bought, when and where you bought it and how you paid for it)
  • Data about your online browsing behaviour on our Websites and information about when you click on one of our adverts
  • Data about what emails you open, and click on.
  • Data about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)

To determine whether the data is relevant, we build a profile of you based on the demographic and behaviour data as described above. This allows us to profile your interests and therefore target you with relevant ads or relevant offers and promotions from brands we work with.

You can opt-out at any point. To do this click on the link marked unsubscribe in the email received from us. Your details will be stored on our system only for suppression purposes. And if we receive your email address again, we will automatically remove you from any further communications from us. This suppression method ensures you will never hear from us again. Alternatively, CLICK HERE to request removal from our marketing activity.

PERSONAL EMAIL DATA WE RECEIVE FROM THIRD PARTIES

A Life Change manages email data on behalf of third parties. Therefore, you may have signed up to receive third party marketing messages via another website or partner, who have then provided us with your details. To do this, you have explicitly opted in for your data to be transferred and used in this manner.

We do the upmost to ensure a valid opt-in exists. The original data controller will provide us with details of the opt-in and then we will audit the opt-in process and the privacy policy. In most cases, we will be named at point of opt-in or you would have opted in to receive marketing messages from certain sectors e.g. charities. If you engage (open/click) on an email from us within the last 365 days, we will continue to mail you. You can opt-out at any point either when you receive an email from us by clicking on the unsubscribe link provided. You can also opt out by CLICKING HERE

Although we do the upmost to validate that the opt-in to the original list owner is valid and correct, we can only do so much to prove this. In some cases, it may be incorrect and if you believe this to be the case, please do contact us and we will investigate promptly.

Along with the email address, the original source may also supply us with other personal information about you, such as age, gender, postcode. This is used to help us profile you and send you relevant marketing messages. If you wish us to remove this information or update it, please contact us

THE TYPE OF MARKETING YOU WILL RECEIVE

We will send you emails which contain marketing messages from brands we work with. The headers and footers within the email will make it clear that we are sending it but the content will be provided by the brand we work with.

The marketing messages you will receive will be relevant to one of the data categories listed below:

Sector Description
Retail Online retail
General stores
Automotive (including Brochures and Test Drives)
Property
Food and Drink
Technology
Home furnishings & Improvements
Fashion and clothing
Telecoms and utilities
Finance Pensions
Loans, credit cards and mortgages
Investments & savings
Claims Companies
Insurance Home
Car
Travel
Pet
Personal and Life
Other insurances
Travel Holidays
Hotel
Airlines
Travel booking
Lifestyle Health & Beauty
Fitness
Charities
Media & publishing companies
Leisure
Gaming
Gaming
Gambling
Educational institutions
Compensation, Legal Services and Personal Injury
Injury Compensation Services
Careers and Education

Public Sector
Mail Order
FMCG
Marketing Agencies & Brokers
SHARING PERSONAL DATA WITHIN THE A LIFE CHANGE GROUP

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis set out in this policy.

SHARING PERSONAL DATA WITH OTHER ORGANISATIONS
We may share personal data with other organisations in the following circumstances:
  • with car, life and home insurance companies in order to deliver the quotation service you requested when you visited our website
  • if the law or a public authority says we must share the personal data;
  • if we need to share personal data to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk);
  • to an organisation we sell or transfer (or enter negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organisation receiving your personal data can use your personal data in the same way as us; or
  • to any other successors in title to our business.
DATA PROTECTION – ACCESSING, UPDATING, RETAINING AND DELETING YOUR PERSONAL DATA

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

(a) Postal address, telephone number and Email address will be retained for a minimum period of 2 years following last click date. We maintain a record of the postal and email address, only to maintain a file of 'do not mail/email’. Any data related to the postal and email address e.g. gender, postcode will be deleted 5 years after the last click date.

In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of postal and email address will be determined based on the requirements to maintain a suppression file of people who have opted out.

Notwithstanding the other provisions of this privacy policy, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

A Life Change adheres to the Data Protection Act 2018, GDPR and PECR. Under this legislation, you have the right to see the personal data we hold about you. This is called a Subject Access Request.

If you would like a copy of the personal data we hold about you, please contact us on the details at the bottom of the page

We want to make sure that the personal data we hold about you is accurate and up to date. If any of the details are incorrect, please let us know and we will amend those details.

YOUR RIGHTS

In this Section , we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:
  1. the right to access;
  2. the right to rectification;
  3. the right to erasure;
  4. the right to restrict processing;
  5. the right to object to processing;
  6. the right to data portability;
  7. the right to complain to a supervisory authority; and
  8. the right to withdraw consent.

You have the legal right to access information we hold about you. If you would like to find out more, please write to us at the address below, alternatively please contact us at info@media-flip.co.uk. You will be asked to evidence the communication you have received from the website, which is needed so we can pinpoint exactly where that communication originated. We do this to protect your personal information in line with the GDPR guidelines of 2018.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims. We will never erase your email address, so we can maintain a record that we should not mail you In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to mail you.

To the extent that the legal basis for our processing of your personal data is:

(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you are 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 which in the UK is the Information Commissioner’s Office whose address is Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. If you wish to withdraw your consent, you can do so by CLICK HERE

DATA SECURITY

A Life Change has appropriate industry standard technology, physical and administrative procedures in place for a company of our size and complexity to protect the data that is collected and stored. Our software is kept up to date with the latest releases to protect against industry known vulnerabilities.

From time to time we may ask other members of our group, or third party service providers, to help us manage our information technology systems. Some of these systems may be located in countries overseas, including countries located outside the European Economic Area (EEA).

We will only transfer your information to a third party service provider or overseas, where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any information being processed and compliance with applicable privacy and data protection laws. These measures may include the use of Standard Contractual Clauses, the EU-US Privacy Shield, Swiss-US Privacy Shield or your consent. You may request further information on the legal security measures used for such transfers via the contact details given in this Privacy Notice.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies, such as tags and pixels ("Cookies") on both our websites and emails we send you. These are used to personalise and improve your customer experience and to provide you with relevant online advertising on websites and via email.

Cookies are small data files that allow us to store settings and identifiers on your desktop computer, laptop or mobile device.

Cookies help us to provide important features and functionality on our Websites and Mobile Apps, and we use them to improve your customer experience. For example, we use Cookies to do the following:

• Personalise our websites and Mobile Apps for you by remembering your preferences so that you can continue where you left off if you return to a site. This data is stored locally and we do not store this data on our servers.

We also use cookies for Site Abandonment. This is where we place a script on a partner’s website and when you visit their website, our script looks to see if an A Life Change owned cookie exists on your browser. If it exists it triggers an email to be send on the behalf of the advertiser but we will be identified as the data controller and sender. These emails will only be triggered if you have accepted cookies on their site and we have a valid opt-in for you. These will be marketing messages from the owner of that website aimed at improving your interaction with their website.

We may also use cookies for trigger paths, this is where we send a marketing email that has been designated as relevant to individuals that have interacted with an email of ours that you have opened or clicked on.

DELIVER RELEVANT ONLINE ADVERTISING

Cookies help us to deliver online advertising we believe is relevant to you on our Websites, other organisations’ websites and through emails we send you.

Cookies used for this purpose are placed on your device by one of our websites or partner websites, emails we send you or on our Websites by other organisations, and always with your permission. These Cookies store information about your online activity, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. They may also contain an identifier that links to your email address.

These cookies enable us to control the frequency and the number of times you may see an advert on your different devices. The cookies also help our advertisers identify potential customers who they feel are relevant for their products.

This means that you may see our adverts or adverts from brands we work with on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.

To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected, for example what emails you have opened or the postcode you provided to us or through one of our partners when you opted-in.

MEASURING THE EFFECTIVENESS OF OUR MARKETING AND ADVERTISING

Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.

We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you and if this email was advertising a partner, whether you have then clicked through onto the partner’s website and made a purchase.

Cookies we use:

Cookie Purpose
Google Analytics These cookies allow us to collect information about how visitors use the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google
Google Adsense Google uses cookies to serve more relevant ads across the web and limit the number of times a given ad is shown to you. When you visit a website, view an ad, or click an ad supported by Google’s advertising services, Google may set a cookie on your browser. This advertising cookie will appear in your browser as coming from the domain "doubleclick.net". Learn more about Googles Policies
Lotame Data management platform, for the purpose of gaining audience insights and enabling consented audience data to be activated on the below platforms. Lotame uses cookies and other identifiers to track online behavioural, demographic and technographic data; they don’t receive information such as your name and email. Lotame can also receive anonymous data segments that The Race sends, such as user IDs associated with people who have been registered members for a certain length of time. Lotame stores data on average for 9 months, and in special cases for up to 18 months. Lotame’s privacy policy: https://www.lotame.com/about-lotame/privacy/lotames-products-services-privacy-policy
LiveRamp (Acxiom Limited) When you use our website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating LIVERAMP CONFIDENTIAL 4 system, with our partner, LiveRamp Inc and its group companies ('LiveRamp’). LiveRamp may drop a cookie on your browser or directly in our emails and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. Similarly, when you use our mobile apps, we may also share hashed and de-identified email addresses, mobile device ID, location data, and advertising identifiers with LiveRamp, which uses that information to create a link between your mobile device and its databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email and in app etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. You have the right to exercise your rights under GDPR including opting out of LiveRamp’s Cookie or Mobile Identifiers and can easily do so by clicking on this link: https://your-rights.liveramp.uk/home
your connection. You can at any time easily oppose the deposit of our cookie by clicking on this link: https://liveramp.uk/cookies-101/.
A Life Change Limited A Life Change’s cookies set an identifier linked to your email address this enables us to identify visitors to our advertising clients’ websites and send them a personalised email or serve them personalized ads via display, social, video or mobile. To opt out of A Life Change Email please CLICK HERE

You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or another device. You can find more detailed information about how you can manage Cookies at the All About Cookies and Your Online Choices websites.

HOW TO CONTACT US

If you have any questions, complaints or suggestions regarding this policy or our data practices, please email or mail us:

info@media-flip.co.uk
or addressed to the Media Flip Data Protection Officer, Kemp House, 152 - 160 City Road, London, United Kingdom, EC1V 2NX

A Life Change is a trading name of Media Flip Ltd, company number and is registered as a Data Controller with the Information Commissioners Office under registration number ZA298146.We aim to comply with The Data Protection Act 1998, the Privacy and Electronic Communications Regulations 2003, the EU regulations 2011 and the General Data Protection Regulations of 2018.

CHANGES TO THIS PRIVACY POLICY

A Life Change will occasionally update this privacy policy. When we do, we will also revise the last updated date.

A Life Change website owned and operated by Media Flip Limited