Privacy and Personal Data Policy
This policy explains the types of personal data we (JP Money Ltd T/A Charterwells) may collect about you when you interact with us.
We collect and process data in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679.
We do not disclose data to any third parties unless disclosure is necessary for the fulfilment of a service; you have specifically given consent for a particular service, or we have a legitimate interest in disclosing data.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is
Old Brewery House
189 Stanmore Hill
Tel: 0208 816 8589
VAT reg no 994318971
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
b). The right to access the personal data we hold about you.
c). The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us.
d). The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.
e). The right to restrict (i.e. prevent) the processing of your personal data.
f). The right to object to us using your personal data for a particular purpose or purposes.
g). The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Data Do We Collect?
Depending upon the type of work we may collect some or all of the following personal data:
National Insurance number
Tax reference codes
Date of birth
Information about your preferences and interests;
Web browser type and version;
Operating system; and
A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
Providing and managing your access to Our Site.
Supplying Our services to you. Your personal details are required in order for us to enter into a contract with you.
Personalising and tailoring our services for you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking unsubscribe in the relevant email or notifying us at firstname.lastname@example.org.
Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below.
Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We do not use automated systems for carrying out decision-making.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
(a). The objectives and requirements of the Company;
(b). The type of personal data in question;
(c). The purpose(s) for which the data in question is collected, held, and processed;
(d). The Company’s legal basis for collecting, holding, and processing that data; and
(e). The category or categories of data subject to whom the data relates.
If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.
Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).
In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.
How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
Technical Data Security Measures
All emails containing Personal Data must be encrypted;
All emails containing Personal Data must be marked ‘confidential’;
Personal Data may only be transmitted over secure networks;
Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
Personal Data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
Where Personal Data is to be transferred in hardcopy form, it should be passed directly to the recipient in accordance with this Policy;
All Personal Data transferred physically should be transferred in a suitable container marked “confidential”;
No Personal Data may be shared informally and if access is required to any Personal Data, such access should be formally requested from the DPO;
All hardcopies of Personal Data, along with any electronic copies stored on physical media should be stored securely;
No Personal Data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;
Personal Data must be handled with care at all times and should not be left unattended or on view;
Computers used to view Personal Data must always be locked before being left unattended;
No Personal Data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the DPO and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
No Personal Data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;
All Personal Data stored electronically should be backed up regularly with backups stored onsite. All backups should be encrypted;
All electronic copies of Personal Data should be stored securely using passwords and encryption;
All passwords used to protect Personal Data should be changed regularly and should must be secure;
Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;
No software may be installed on any Company-owned computer or device without approval; and
Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the DPO to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
Do You Share My Personal Data?
We may share your personal data with HMRC and Companies House.
We may sometimes contract with the following third parties to supply certain products and/or services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Control My Personal Data?
In addition to your rights under the GDPR, when you submit personal data, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing via the link within the relevant email.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of two months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for Analytics and Visitor trending. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.