Privacy Notice (UK and EEA)
Effective Date: 1 April 2022
This privacy notice applies to Likewize websites located and operated by Likewize entities located in the United Kingdom (UK) and a country within the European Economic Area (EEA). Likewize operates a corporate website controlled by Likewize Corp. and is subject to the Group Privacy statement, which you can view here: https://www.likewize.com/privacy/.
Likewize respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our UK or EEA-based websites (regardless of where you visit it from) or when you provide your data to us to enable us to carry out services or sell goods to you or where your data may be transferred to us by our customers for us to carry out services for them. This notice tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so that you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- Important information and who we are
- The data we may collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Likewize collects and processes your personal data through your use of this website, including any data you may provide through this website or otherwise when you sign up to our newsletter, purchase a product or service, or take part in a competition or where we are asked to process personal information on behalf of one of our commercial customers.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy notice in conjunction with any other privacy notice or fair processing notice we may provide on specific occasions when collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Who we are
Likewize is made up of different legal entities. This privacy notice is issued on behalf of the Likewize entities located in the UK or a country in the EEA, so when we mention “Likewize”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Likewize Group responsible for processing your data. If required, we will let you know which entity will be the controller for your data when you purchase a product or service with us.
We have a dedicated team responsible for overseeing questions about this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us here: GDPRSupport@likewize.com.
You have the right to make a complaint to the relevant supervisory authority for data protection. A list of UK and EU Data Protection Authorities can be found here http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. We would, however, appreciate the chance to deal with your concerns before you approach a Data Protection Authority, so please contact us in the first instance at GDPRSupport@likewize.com.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 1 April 2022.
It is important that the personal data we hold about you is accurate and current. Therefore, please keep us informed if your personal data changes during your relationship with us.
Our websites may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we may collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and other information that you provide as a part of filing a claim (e.g., driver’s licence or passport, national insurance number, shipping, billing, and banking information, mailing address, etc.).
- Device Data includes IP address, Electronic Serial Number (“ESN”) or International Mobile Equipment Identity (“IMEI”) data, and mobile phone number.
- Usage Data includes information about how you use our website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us and your communication preferences.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data 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 goods 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 is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or corresponding with us by post, phone, e-mail, or otherwise. This includes personal data you provide when you, and where relevant, apply for our products or services.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers;
- advertising network;
- search information providers;
- Our commercial customers when we are engaged to provide goods or services to such customers and where this involves processing to personal data provided by the Customer; and
- Online selling platforms may sell Likewize products through platforms that may be based outside the UK or EEA.
- Contact, Financial and Transaction Data from technical, payment, and delivery services providers.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly availably sources.
- Identity and Contact Data from specialist databases such as CheckMend to verify if a mobile device has been lost or stolen or IMEI database searches.
- Technical Data from the following parties:
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party), your interests and fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing by contacting us at GDPRSupport@likewize.com.
Purposes for which we will use your personal data
We have set out below a description of how we plan to use your personal data and which of the legal bases we rely on. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at GDPRSupport@likewize.com if you need details about the specific legal ground we rely on to process your personal data where more than one ground has been set out below. Below we set out the likely purposes of using your personal data if you have provided your data for the purpose or activity referred to. If you have not provided your personal data for any of the specific purposes listed, then we will not use it for that particular purpose.
We strive to provide you with choices regarding certain personal data uses, particularly marketing and advertising. We have established the following personal data control mechanisms:
- Promotional offers from us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you or our commercial customers (we call this marketing).You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We may also use the data we hold about you to invite you to events that may be relevant or of interest to you and your business. We may also use this data to invite you to participate in surveys that allow us to measure customer feedback and opinions.
- Third-party marketing
We will get your express opt-in consent before sharing your personal data with any company outside the Likewize group for marketing purposes.
- Opting out
You can ask third parties or us to stop sending you marketing messages by contacting us at GDPRSupport@likewize.com.Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us due to a product/service purchase, warranty registration, product/service experience, or other transactions.
- Promotional offers from us
Likewize may receive personal data from its commercial customers as part of its services to those customers. In such a case, it would generally be the customer that is the data controller, and Likewize is the data processor. We will not use that personal data for any purpose other than the fulfilment of our contractual obligations to that customer or in accordance with the customer’s instructions.
Third-party sales platforms:
Likewize may, from time to time, use third-party sales platforms to sell its products. The platform operator manages the sales transaction and collection of personal data and may share the personal data with Likewize to enable Likewize to deliver products to the buyer or person nominated by the buyer, which may include name, address and contact details. Additional information may be provided for any additional services ordered or product warranty records. Personal data will only be used for the purposes for which it is provided.
The personal information we have collected from you may be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by www.cifas.org.uk/fpn and https://www.synectics-solutions.com/privacy-policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at GDPRSupport@likewize.com.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in this privacy notice.
- Internal Third Parties (as set out in the Glossary);
- External Third Parties (as set out in the Glossary);
- Specific third parties listed in paragraph 3 above;
- Our commercial customers in fulfilment of our contractual obligations to them; and
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other companies or merge with them. If a change happens to our business, the new owners may use your personal data the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data within the Likewize Group. This will involve transferring your data outside the UK or the EEA.
Many of our external third parties are based outside of the UK or the EEA, so their processing of your personal data will involve a transfer of data outside those jurisdictions. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Secretary of State for the Home Department or the European Commission. For further details, see the European Commission: Adequacy of the protection of personal data in non-EU countries and the UK Secretary of State for the Home Department: Adequacy regulations; or
- Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioner’s Office or the European Commission, which give personal data the same protection it has in the UK or Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries and the UK International Data Transfer Agreement and Addendum to the 2021 EU Standard Contract Clauses; or
Please contact us at GDPRSupport@likewize.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other regulatory purposes.
In some circumstances, you can ask us to delete your data: see Request erasure below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at GDPRSupport@likewize.com. For more information on these rights, please see the Glossary below.
No fee is usually required
You will not have to pay a fee to access your personal data (or exercise any other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you regarding specific activities by contacting us at GDPRSupport@likewize.com.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies in the Likewize Group acting as joint controllers or processors based in the US, UK or an EEA country and provide IT and system administration services and undertake leadership reporting.
External Third Parties
- Service providers acting as processors based in the US who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom or relevant EEA country who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which we will notify you about, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format to you or your chosen third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case when you withdraw your consent.