Plumb App Uk Privacy Policy

WEBSITE & APP PRIVACY POLICY

Introduction
1. The website 'www.plumbapp.co.uk' (the Website) and the app 'Plumb App UK' (the App) is owned and operated by Plumb App UK Limited ( "We").
2. This privacy policy will inform you as to how we collect, process and look after your personal data when you visit our Website and use our App, including any personal data you may provide through this Website and our App. If you do not agree with this policy, you must not use the Website or the App.
3. We process different types of personal data for different reasons. For some personal data we will be the data controller, for other personal data we will only be a processor of that data:
  1. In respect of the personal data of users of the App (the "App User") or our template website add on service, our business contacts and prospects, third party suppliers and other customers, Plumb App UK Limited is the data controller.
  2. Our App and template website service is used by App Users to assist with their booking processes and website hosting. In using our App, the App User will share data about their customers with us. In respect of the personal data of any customers of the App User, we shall process personal information as a data processor on behalf of the App User. Where you are a customer of an App User, the privacy policy of that App User, rather than this privacy policy, will apply to our processing of your personal information.
4. If you have any questions about this privacy policy or how and why we process personal data, including whether we act as controller or processor of your data, please contact us using the details at the foot of this policy.
5. This privacy policy does not cover personal data which may be collected by other websites, apps or third parties, such as payment providers, please check their privacy policy for more information.
Purpose of this privacy notice
1. It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
2. The following policies also apply to your use of our Website, App and Services:
  - our Service Terms and Conditions;
  - our Acceptable Use Policy;
  - our App Terms and Conditions; and
  - our Cookie Policy.
Changes to the privacy notice and your duty to inform us of changes
1. This version was last updated on 27 October 2021.
2. We may change this privacy policy from time to time. If so, we will notify you by: SMS; email; in-app message; website update or otherwise.
3. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
Third-party links
1. Our Website and App may include links to third-party websites, apps, 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 or apps and are not responsible for their privacy statements. When you leave our Website or App, we encourage you to read the privacy notice of every website you visit or app you use.
The data we collect about you
1. 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).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
  - Identity Data includes first name, last name, title, date of birth, profile picture, location, gender, criminal convictions and offences.
  - Contact Data includes billing address, delivery address, email address and telephone numbers, contact data.
  - Financial Data includes bank account and payment card details, and details of your trade insurance requirements.
  - Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  - Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location tracking, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website and App.
  - Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  - Usage Data includes information about how you use our Website and App, products and services.
  - Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  - Location Data includes your current location disclosed by GPS technology.
  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 or App 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.
3. 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).
If you fail to provide personal data
1. Where we need to collect personal data by law, or under the terms of a contract we have with you. If 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.
How is your personal data collected?
1. 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 by corresponding with us by email or otherwise. This includes personal data you provide when you:
    - create an account on our Website and App;
    - subscribe to our service;
    - subscribe to our template website service add-on;
    - request marketing to be sent to you;
    - use the services within the App or Website;
    - enter a competition, promotion or survey; or
    - give us some feedback.
  - Automated technologies or interactions. As you interact with our Website and App, we may automatically collect Technical Data about your location, equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, location tracking and other similar technologies. Please see our Cookie Policy for further details.
  - Third parties or publicly available sources. We may receive personal data about you from various third parties, if we do, we will notify you.
  - Location Data. We also use GPS technology to determine your location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
How we use your personal data
1. 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) and your interests and fundamental rights do not override those interests.
  - Where we need to comply with a legal or regulatory obligation.
  - Where you have given your consent to receive third party direct marketing.
2. We use the following types of lawful basis to process your personal data:
  - 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 we process 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 in respect of specific activities by contacting us.
  - 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, such as subscribing to our services.
  - 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.
3. 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 email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
2. 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 if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new user and to provide the services via the App and the template website page

(a) Identity

(b) Contact

(d) Financial

(e) Transaction

(f) Technical

(g) Profile

(h) Usage

(i) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to improve performance of the App and template website page)

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To share your data with carefully chosen third party sponsors, so that they can provide you with an insurance renewal quote and/or subscribe you to their email newsletters.

(a) Identity

(b) Contact

(d) Marketing and Communications

We only do this where we have your consent

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this Website and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Website and App content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

(g) Location

a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

(b) We only use location data with your consent.

To use data analytics to improve our Website and App, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

(a)Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website and App updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(a) Necessary for our legitimate interests (to develop our products/services and grow our business)

To use our auto-fill feature to populate any forms which you generate using our services.

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(a) Performance of a contract with you

To facilitate your application to be an introducer appointed representative

(a) Identity

(b) Contact

(d) Financial

(a) Performance of a contract with you

Promotional offers from us
1. We may use your Identity, Contact, Technical, Usage, Location 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 (we call this marketing).
2. You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
1. We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
Opting out
1. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Change of purpose
1. 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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
3. 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.
Disclosures of your personal data
1. We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 9 above.
  - Other companies in our group, including Gas App UK Limited
  - HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances;
  - Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
  - MailChimp acting as processors based in the US who send emails on our behalf;
  - Competition sponsors as processors who we disclosure your full name and email address to if you enter a competition for verification purposes;
  - Other service users, your name and profile photo are disclosed if you make a post or comment on our Website or App;
  - Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice;
  - App developers as processors with the servers based in the US;
  - Service providers acting as processors based in the EEA such as IT and system administration services, platform providers, website hosts.
2. We require all third parties to respect the security of your personal data and to 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.
International transfers
1. We do not transfer your personal data outside the United Kingdom (UK other than sharing your name and email address with MailChimp provided by The Rocket Science Group and all your PERSONAL DATA with Exploding Phone Limited. This will involve transferring your data outside the United Kingdom (UK). Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
2. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
3. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
1. 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.
2. We will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

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.

Type of data	Retention period	Reason for retention
Identity	14 days following the termination or expiry of this agreement. Criminal convictions and offences data will be deleted immediately once the data has been passed to Phoneix Financial Consultants.	To allow you to request the data to be returned following the termination or expiry of this agreement.
Contact	14 days following the termination or expiry of this agreement.	To allow you to request the data to be returned following the termination or expiry of this agreement.
Financial	14 days following the termination or expiry of this agreement.	To allow you to request the data to be returned following the termination or expiry of this agreement.
Transaction	14 days following the termination or expiry of this agreement.	To allow you to request the data to be returned following the termination or expiry of this agreement.
Technical	14 days following the termination or expiry of this agreement.	To allow you to request the data to be returned following the termination or expiry of this agreement.
Profile	14 days following the termination or expiry of this agreement.	To allow you to request the data to be returned following the termination or expiry of this agreement.
Usage	14 days following the termination or expiry of this agreement.	To allow you to request the data to be returned following the termination or expiry of this agreement.
Marketing and communications	14 days following the termination or expiry of this agreement.	To allow you to request the data to be returned following the termination or expiry of this agreement.

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.

Your legal rights
1. Under certain circumstances, you have rights under data protection laws in relation to your personal data, these include the following rights of request:
  - 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 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 data we hold about you corrected, though 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 continuing 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 will be notified to you, 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 which makes you want to object to processing on this ground as you feel it impacts on 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 to a third party. 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 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 at the time you withdraw your consent.
2. If you wish to exercise any of the rights set out above, please contact us.
3. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
4. 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.
5. 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.
Queries and complaints
1. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
2. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) about how we are dealing with your personal data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Contact information
Company Name: Plumb App UK Limited

Company Number: 12877790

Primary Office: Shakespeare Buildings, 26 Cradley Road, Cradley Heath, West Midlands, United Kingdom, B64 6AG

Email Address: support@plumbapp.co.uk

Last Updated: 2021-11-01 14:28:41