When we first obtain Personal Data from you, or when you take a new service or product from us, we will give you the opportunity to tell us if you do or do not want to receive information from us about other services or products (as applicable). You can normally do this by ticking a box on an application form or contract. You may change your mind at any time by emailing us at the address below.
1. Collecting Information
We may collect Personal Data about you from a number of sources, including the following:
- From you when you explicitly agree to take a service or product from us, in which case this may include your contact details, how you will pay for the product or service and your bank details.
- From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services, but only with explicit permission, including double opt-in.
- We do not collect any data that is regarded as high risk or sensitive.
- When you first give us Personal Data through the Website, we will ALWAYS give you the opportunity to say whether you would prefer us not to contact you by email.
- You can also always send us an email (at the address set out below) at any time if you change your mind.
- It is important that if you write to us, your request (either permission to process or request to remove) should be presented in a manner which is clearly distinguishable for any other matters.
- We do not knowingly collect data from anyone under the age of 16, and will remove details of anyone, should data be found to be owned by anyone under 16.
- We will only user the data provided by you for the purpose it was intended by you.
2. How we use your data
- Personal Data about our customers is an important part of our business, we shall only use your Personal Data for the following purposes and shall not keep such Personal Data longer than is necessary to fulfil these purposes:
- To help us to identify you when you contact us.
- To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time.
- To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future.
- To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information.
- To help to prevent and detect fraud or loss.
- To allow us to contact you in any way (including mail, email, telephone or visit) about products and services offered by us and selected partners unless you have previously asked us not to do so.
- We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.
- We may check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we will record this.
- We may allow other people and organisations to use Personal Data we hold about you in the following circumstances:
- If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case Personal Data held by us, about our customers, will be one of the transferred assets.
- If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.
- In connection with any transaction which we enter into with you:
- We, and other companies in our group, may carry out credit and fraud prevention checks with one or more licensed credit reference and fraud prevention agencies. We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be considered in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.
- If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.
- If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please contact our data protection officer using the details provided below.
- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
- All Mentor Group staff are trained on GDPR and are obligated to hold up its content and ethos.
3. Protecting your data
We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we hold. We also have strict policies in place to ensure data is secure when being transferred.
- We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
- Any data we hold is only accessible to you and any relevant employees,
- We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
- It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
- We will ensure that if there is a data breach, we will inform you and the Supervising Agency without undue delay and, where feasible, within 72 hours of us being made aware.
- Where, and in so far as, it is not possible to provide the information at the same time, the information may be provided in phases without undue further delay.
- Mentor Group will, at all times, align and adhere to GDPR codes of conduct and monitoring that may be given by the official Supervising Agencies.
- Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of GDPR.
- We may have to transfer personal data to a third country or an international organisation but only if we have provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available.
- Where personal data is transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate relating to the transfer.
- Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through several countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.
- Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.
- The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy.
- The data subject shall have the right to mandate a not-for-profit body, organisation or association which has been properly constituted in accordance with the law of a Member State, has statutory objectives which are in the public interest, and is active in the field of the protection of data subjects’ rights and freedoms with regard to the protection of their personal data to lodge the complaint on his or her behalf.
5. Further Information
- If you would like access to the Personal Data that we hold about you, you can do this by emailing us at firstname.lastname@example.org or writing to us at the address noted above. We will respond to your request within one month of receipt.
- If for any reason we are unable to provide the data we will inform the you without delay, and at the latest within one month of receipt of the request, of the reasons for not taking action and on the possibility of you lodging a complaint with a supervisory authority and seeking a judicial remedy.
- This service will be free of charge except where the requests are manifestly unfounded or excessive. In such cases we reserve the right to charge a reasonable fee to cover the time and resources or refuse to act on the request.
- If you would like any data we hold about you amended or removed, please write to us at the above address or email us at email@example.com.
- Any request for such information needs to be backed up with relevant and suitable evidence of identity.
- We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly.