We, Switchly, are committed to safeguarding the privacy of consumers; this policy sets out how we will treat your personal information.
We are a trading style of Ropto Limited (Ropto). Ropto is registered in England and Wales under company registration number 08915874. Our registered office address is Hamilton House, Church Street, Altrincham, WA14 4DR.
We are a Data Controller, which means that we determine the purposes and the means of processing your personal information. We are registered directly with the Information Commissioner’s Office (ICO) and our registration number is ZA044830.
HOW WE COLLECT YOUR PERSONAL INFORMATION
Most of the personal information we collect will be collected directly from you when you register for and use our services or interact with communications we send to you. We will collect this information from you through our websites, mobile applications or other similar devices and our communications with you.
FROM A SERVICE PROVIDER
As part of our services, with your consent, we may facilitate a referral to a chosen Service Provider. The Service Provider may send us information they hold relating to your engagement with them and any products you have purchased. This allows us to track sales and improve our services.
FROM ONE OF OUR PARTNERS
We work with partners who may promote our services to you. If you are interested in our services, you will be able to ask for our partner to pass your personal information to us, to allow us to get in touch with you. Our partners will only ever pass your personal information to us with your consent.
OTHER SOURCES OF PERSONAL DATA
We may also use personal data from other sources, such as specialist companies that supply information, online websites, and social media channels. These other sources help us to:
Review and improve the accuracy of the data we hold
Improve and measure the effectiveness of our marketing communications, including online advertising.
THE PERSONAL INFORMATION WE COLLECT
Identity information - This is information that helps us identify who you are, for example your title, name, and date of birth.
Contact information - This is information that details how we can contact you, for example your address, email and/or telephone number.
Financial information – When you provide your bank details or payment information when using our services.
User information - This is information collected about you as a user of our services. For example, to provide you with a utility comparison service we require information about your utility provider, and energy use.
Interaction information - This is information about how you interact with our services and communications, namely what you click on and interact with on websites or other media channels and any emails we send to you.
Technical information - This is information about how you use our websites and other media channels. This could be information that identifies your device, its operating system, internet address, your login data, your location, where you were directed to our website from and where you leave to, as well as how often you visit.
HOW WE USE YOUR PERSONAL INFORMATION
TO PROVIDE OUR SERVICES TO YOU
passing your personal information to our Service Providers, with your consent, so they can contact you about or provide their services;
storing your personal information and using it to populate fields on our websites to make it easier for you to utilise our services in the future;
obtaining information from our Service Providers about your engagement with them and products you have purchased;
contacting you to see how we can help if you have not completed your journey with us, or with a Service responding to any enquiries that you make via email, post, or social media; and
keeping in touch with you about annual renewal; if you obtain a quote from us for a product or service that renews annually we may use the information you have provided to contact you to see if you we can help you further when our systems indicate that your renewal is due.
What is our legal basis for processing?
Performance of a contract; or
TO MARKET TO YOU
contacting you about products and services which we think may be of interest to you, for example, by email, post, or social media; and
inviting you to take part in and manage consumer surveys, reviews, and other market research activities.
Should you no longer wish to receive information about similar products and services, you can withdraw your consent for or object to receiving marketing communications from us and we will stop processing your data for marketing purposes. You can object via email or post using the contact details at the end of this policy.
What is our legal basis for processing?
TO PERSONALISE YOUR JOURNEY WITH US
using your personal information to form a view on what services you may be interested in and tailor our marketing communications to you;
This is called profiling. We believe we have a legitimate interest to do this and that it does not harm your rights over your information. However, if you do not want us to use your personal information in this way you have a right to object to this and can let us know using the contact details at the end of this policy.
Internal Analysis: we may use your personal data to assess our performance as a business and for statistical analysis, as part of our legitimate interest to develop our business and our products; and
Sale, or re-structuring: we may share your data with potential buyers of some or all of our business during a sale, or re-structuring and may rely on legitimate interests to transfer ownership of your files with us to a third party.
What is our legal basis for processing?
We may be required to use your data due to a legal requirement which is placed upon us; this includes our regulatory requirements such as financial record keeping, staff training and monitoring, in addition to complaint handling. We will always inform you if this is the case.
What is our legal basis for processing?
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
To allow us to provide our services to you and, where relevant, facilitate a referral to your chosen Service Provider, we also utilise other third parties to provide critical functions to our business. Your personal data will always be processed in strict confidence and we will take all reasonable steps to ensure that any third party has adequate security measures in place.
Systems and IT: we use third party firms which support the running of our business through providing essential data storage, software, and other IT services;
Communicating with you: we may use third party platforms to manage and send some of our email and text message (SMS) communications and may use an outsourced print house to print and post letters that we send to you;
Analysis and personalisation: we use third party firms for analysis and to help personalise our website and communications to ensure consumers they are provided with the best experience;
Meeting our obligations: we may use professional legal, consultancy and accountancy services to help us fulfil our regulatory and legal obligations. In certain circumstances we may be required to provide your data to our Regulator, or other relevant body, for example the Financial Conduct Authority, the Financial Ombudsman Service, the Information Commissioner’s Office, or a law enforcement body;
Credit Information Services: We may share information with and use information from credit reference agencies to:
ensure the information we hold about you is correct and up to date; and
perform a “soft” credit check with the credit reference agency, where this is relevant to the service we are providing to you. “Soft” checks are visible to you on your credit report but do not show up to other organisations in the same way as a “hard” check and have no impact on your credit rating. We will always notify you prior to performing a “soft” check on your credit report.
Other third parties: we may share your data with other third parties where we believe we have a legitimate interest to do so, such as tracing agents, review platforms, market researchers, or potential buyers of some or all of our business during a sale, or re-structuring.
If you request for us to stop processing your data, we will also communicate this to the relevant third parties if they are processing this on our behalf. If you have any concerns about the above third parties, please let us know and we can provide advice and support to help you manage your data preferences.
We will only share your personal information outside the United Kingdom (UK) where we have your consent, to comply with a legal duty, or where we work with a third party service provider to enable us to provide you with our services, and they process information outside of the UK. If we do share your information outside of the UK, we will make sure that it is protected in the same way as if it was being used within the UK.
This includes through ensuring that the transfer is covered by an appropriate safeguard or that the European Commission has made an ‘adequacy decision’ in respect of the country’s data protection measures. Although we are no longer part of the European Union (EU) the UK Government has recognised European Commission adequacy decisions made before the end of the transition period, meaning we are able to continue to transfer data to the European Economic Area (EEA) and other countries with a European Commission adequacy decision in confidence, knowing that the appropriate safeguards are in place to ensure personal data is kept safe. More information on this can be found on the European Commission Justice website or the Information Commissioner’s Office website.
In addition, some of the third party service providers we use that are based in the UK or EEA may provide services which mean your data is transferred outside of the EEA.
In any case, we ensure that there are appropriate security measures in place such as technical security, including encryption and restricted access to your data. We have strict contracts in place to make sure your data is kept safe. If you have any questions, please contact us.
OUR LEGITIMATE INTERESTS
Where we have mentioned in this policy that our use of your personal data is based on our “legitimate interests”, these are:
to service our consumers needs and deliver services;
to promote and market our products and services;
to understand consumers including their patterns, behaviours as well as their likes and dislikes; and
to test and develop new products and services as well as improve existing ones.When we rely on our legitimate interest, we make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data.
AUTOMATED DECISION MAKING AND PROFILING
Automated decision making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
As profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.
We only want to contact you about services that will benefit you. To support this may rely on automated decision making as part of our marketing strategy and some of the communications we send to you may be prompted by automated decision making.
You have the right to object to us profiling you for marketing purposes, or using automated decision making. You can object using the contact details at the end of this policy. Where we receive an objection from you, we will stop processing your personal information in this way within one month and confirm this to you.
HOW LONG WE USE PERSONAL DATA FOR
Where we are processing your personal information under the lawful basis of consent, we will keep your data for two years, unless you refresh your consent by interacting with one of our websites or communications during this period and agree for us to continue to process your data.
Generally, you can expect us to keep your personal information while you use our services or if you have an active account with us. Where you have applied for or purchased a products or services through us, we will need to keep your personal information for longer for legal or regulatory purposes, usually up to six years from the date the information is provided to us.
YOUR DATA RIGHTS
You remain in control of your personal information and have rights over the personal information we hold, we summarise some of these rights below. You can make a request to exercise your rights by post or email. If you make the request by email, we will provide any response or information in a commonly used electronic format unless you instruct us otherwise. Where you make a request to exercise one of your rights, we will action this within one month. However, should the request be complex we can extend this by a further two months.
ACCESSING YOUR PERSONAL INFORMATION
You have the right to request from us a copy of the personal data that we may hold about you. This is often called a ‘Data Subject Access Request’. We will provide this free of charge. However, if you make a repeat request, we may charge an administrative fee of £10.
Before providing this information to you or to another person or company, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we are only providing it where you have given your agreement.
CORRECTING YOUR PERSONAL DATA
If the personal information we hold about you is incorrect, or incomplete you have the right to request that we correct this.
STOPPING, OR LIMITING THE PROCESSING OF YOUR PERSONAL DATA
You may request that we stop processing your data, for a specific purpose or any purpose if you believe we are no longer entitled to process it. There may be occasions where we are unable to stop processing your personal data and we will discuss this with you when responding to your request.
DELETING YOUR PERSONAL DATA
If you believe that we no longer have any reason to process or hold your data, you may request that we delete this. There may be occasions where we are unable to delete your personal data due to contractual, legal, or regulatory obligations. We will, however, discuss this with you when responding to your request.
TRANSFERRING YOUR PERSONAL DATA
You can request your data in a commonly used electronic format, and for us to transfer this to another entity or person, where we are processing your data with your consent or in accordance with a contract. This will only apply to information which is processed by automated means.
Cookies are a widely used form of technology and most, if not all, websites will set cookies. Cookies may be used for various purposes, including:
User preferences, including language
Authentication: to identify the user once logged in, for the duration of a session
Analytics: to provide information about website use and user profile
We may use both “session” cookies and “persistent” cookies on the website. We will use the session cookies to keep track of you whilst you navigate the website. We will use the persistent cookies to enable our website to recognise you when you visit. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
We use a mix of cookies. Some of these are set by our website, to manage your preferences. We also use third party cookies. This includes Google Analytics, who gather all of your information on an anonymised basis. This allows us to make sure our website is the best it can be. Most third party cookies are on an anonymised basis, which means these organisations are not collecting any information that can be used to identify you.
We also integrate with social media providers, to help you to connect your account to our website and also to display advertising content which is relevant to you. These cookies use your personal data to deliver advertising which is relevant to your interests.
This is an overview of our cookie use which you can review to decide how best to manage your online privacy:
Functional Cookies - these are always enabled as they are required for basic website maintenance. We cannot stop these from being set on your browser, but you can manage your preferences through your browser itself.
Performance Cookies – These cookies allow us to improve the site’s functionality by analysing usage of our website on an anonymised basis. In some cases, these cookies improve the speed with which we can process your request or allow us to remember site preferences you have selected. De-selecting these cookies may result in poorly tailored recommendations and slow site performance.
Social Media and Advertising Cookies – Social media cookies offer the possibility to connect you to your social networks and share content from our website through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond our websites. This means the cookie will help show you adverts relating to your interests. De-selecting these cookies may result in seeing advertisements that are not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.
You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.
If you have any questions about this policy or our treatment of your personal data, please contact us:
By email at firstname.lastname@example.org
By post to Switchly, Ropto Limited, Hamilton House, Church Street, Altrincham, Cheshire WA14 4DR.
Where provided electronically, a paper copy of this policy can be made available upon request.
If you are not happy with how we process your personal information you should contact us to make a complaint. If you are not happy with how we have dealt with your complaint, you have the right to make a complaint with the Information Commissioner’s Office. You can find their details on their website at https://ico.org.uk/