- Who we are and how to contact us
- Your rights relating to your Personal Data
- Marketing communications preferences
- What Personal Data we collect
- How we use your Personal Data and why
- What happens when you do not provide necessary Personal Data?
- Personal Data from Third Party Sources
- Who we share your Personal Data with
- How we keep your Personal Data secure
- How long we store your Personal Data
- Third party links
- Our policy on children
Who we are.
Our address is: Portland House, Glacis Road, P.O. Box 475.
How to contact us.
Your rights in connection with your Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to 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 information we hold about you corrected.
- 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 continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. 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. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Services. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown here Who We Are and How to Contact Us.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
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 any person 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.
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 a number of requests. In this case, we will notify you and keep you updated.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
You may receive “push notifications” via our Apps which contain marketing materials. You will be asked whether you wish to receive these push notifications when you download and install an App. You do not have to accept such notifications. If you do accept push notifications, you may disable these at any time via your device’s app settings. Wonderwill will not otherwise send you any marketing communications.
When you opt out of receiving push notifications, this will not apply to support and administrative emails we need to send to you from time to time regarding your use of the Services including, for example, changes to our terms and conditions and policies, updates to our Services and security alerts.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, date of birth.|
|Contact Data||Email address, telephone numbers and address.|
|Financial Data||Bank account and payment card details.|
|Transaction Data||Any details about payments to and from you and other details of services you have purchased from us. Data in respect of your transactions with third parties.|
|Service Data||Your data that you provide to us when you report a problem or ask a question in respect of our Services or when you request further services from us. If you contact us, we may keep a record of that correspondence.|
|Technical Data|| This includes:
Unique application numbers: When you install or uninstall an App containing a unique application number or when such an App searches for automatic updates, that number and information about your installation, for example the type of operating system, may be sent to us.
|Behavioural Data||Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into “segments” (e.g., there may be a segment for men, living in London and aged under 25, who like sports).|
No Special Categories of Personal Data
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.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally we do not rely on your Consent as a legal basis for using your Personal Data.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
||To register you as a new customer.||Contractual Necessity.|
|To process payments||
||To process and deliver your order including manage payments, fees and charges.||Contractual Necessity.|
|Fraud prevention and to assess financial, insurance, credit, sector and security risks||
||To keep our services and associated systems operational and secure.||Legitimate Interests.
We have a legitimate interest in ensuring the ongoing security and proper operation of our services.
||To track issues that might be occurring on our systems and to notify you of updates and security alerts.||Legitimate Interests.
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Services and associated systems and services.
|Data analysis, and improvements to our Services||
||To carry out audits and data analysis to identify usage trends, improve the Services and improve the effectiveness of our communications.||Legitimate Interests.
It is in our legitimate interests that we are able to use audit and data analysis to improve the Services and improve the effectiveness of our communications.
||To provide customer service, including to respond to your enquiries and fulfil any of your requests for information in respect of the Services.||Contractual Necessity.|
|To fulfil our obligations under, and enforce the terms of, our agreement with you||
||To fulfil our obligations under, and enforce the terms of, our agreement with you.||Contractual Necessity.
It is in our legitimate interests that we are able to enforce the terms of our agreement with you.
||To personalise your experience on our Apps by presenting information tailored to you and your geographic location.||Legitimate Interests.
It is in our legitimate interests that we are able to provide a more personalised service to you to improve your experience of the Services.
|Compliance with law and regulation||
Where we need to process your Personal Data either to comply with law, or to perform 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 the functionalities of the Services).
In this case, we may have to stop you using our Services have with us but we will notify you if this is the case at the time.
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available?||Category(ies) or other types of personal data received.|
|Credit Reference Agencies||No||
What are cookies?
We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Sites.
Cookies we use
Our Sites use the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Strictly Necessary Cookies||These cookies are essential to provide you with services available through our Sites and to enable you to use some of their features. For example, they allow you to log in to secure areas of our Sites and require you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies are used to recognise you when you return to our Sites and allow our Sites to remember choices you make when you use our Sites, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Sites which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Sites. We also use these cookies to obtain information about your visit, including items you viewed or searched for, page response times and download errors.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Sites. The information collected is aggregated and anonymous. It includes the number of visitors to our Sites, the websites that referred them to our Sites, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our Sites more efficiently, for example, by ensuring that users are finding what they are looking for easily, as well as to gather broad demographic information and to monitor the level of activity on our Sites. We also use these cookies to obtain information about your visit, including the full Uniform Resource Locators (URL) clickstream data, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from webpages.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Sites work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Sites.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
You can also prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout and download and install the linked add-on for your current web browser. The Google Analytics Opt-out Browser Add-on is available for Microsoft Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari and Opera.
The table below describes who we share your Personal Data with, what we share and why we share it.
|Recipients||Category(ies) of Personal Data we share||Why we share it||Location(s)|
||Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison etc).||
|IT Service Providers||
||Our service providers provide us with IT and system administration services.||
|Know-your-client (“KYC”) and credit reference agencies||
||We may make periodic searches of, and provide information about you to, credit reference agencies and fraud prevention agencies to manage and take decisions about our relationship or prospective relationship with you. Such information may be used by other credit providers to take decisions about you and your financial associates. A link between you and anyone with whom you have a joint account or similar financial association will be recorded at credit reference agencies, creating a “financial association”. All such associated parties’ information will be taken into account in future applications until you or one of them successfully files a “notice of disassociation” at the relevant credit reference agencies.||
||Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.||
|Regulators and other authorities||
||Authorities may require reporting of processing activities in certain circumstances||
||Our analytics providers will use this information for the purpose of evaluating your use of our Sites, compiling reports on Site activity and providing other services relating to Site activity and internet usage. Our analytics providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on our analytics providers’ behalf.||
As you can see from the above, we share your Personal Data with certain external third parties who are based outside the European Economic Area (“Europe”). Any processing of your Personal Data by these parties will involve an export of your Personal data outside of Europe.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
- Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
- Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above How we use your Personal Data and why, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|Identity Data||For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Data and why)|
|Contact Data||For so long as you remain a customer of ours.|
|Financial Data||For so long as you remain a customer of ours.|
|Transactional Data||For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Data and why)|
|Service Data||For so long as you remain a customer of ours.|
|Technical Data||For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Data and why)|
These Services are not intended for children under the age of 18 and we do not knowingly collect data relating to such children.