We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our | Novel Intelligence Limited | |
Personal data | Any information relating to an identified or identifiable individual | |
Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
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Data subject | The individual who the personal data relates to |
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Personal data we collect about you
When you visit our website or use our services, we will collect certain personal data about you which may include your name and contact information, including email address and telephone number and company details (If you are a business enquiring about our services).
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay you using our services.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- directly from a third party, eg: credit reference agencies; or
- from cookies on our website—for more information on our use of cookies, please see our cookie policy Cookies Policy – Novel Intelligence
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
What we use your personal data for | Our reasons | |
Providing our services to you | To perform our contract with you or to take steps at your request before entering into a contract | |
Preventing and detecting fraud against you or us | For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us | |
Conducting checks to identify our customers and verify their identity
| Depending on the circumstances: —for our legitimate interests | |
To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect our business, interests and rights | |
Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you | |
Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests , ie to be as efficient as we can so we can deliver the best service to you at the best price | |
Statistical analysis to help us manage our business, eg in relation to our customer base | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price | |
Preventing unauthorised access and modifications to systems | Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us; —to comply with our legal and regulatory obligations | |
Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us | |
Updating customer records | Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract; —to comply with our legal and regulatory obligations; —for our legitimate interests, eg making sure that we can keep in touch with our customers about our services | |
Marketing our services to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. | For our legitimate interests, ie to promote our business to existing and former customers |
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in the table below.
Purpose | Processing operation | Lawful basis relied on under the UK GDPR | Relevant categories of personal data | |
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you as required by data protection laws, ie: —the UK GDPR or Data Protection Act 2018; | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))
| —your name, address and contact information, including email address and telephone number and company details if you are a business; —your account details (username) | |
Addressing and sending communications to you about changes to our terms or policies or changes to the services or other important notices | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | —your name, address and contact information, including email address and telephone number and company details if you are a business —your account details (username) |
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How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers and promotions.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at [email protected] or
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services to you, eg payment service providers;
- other third parties we use to help us run our business, eg marketing agencies or website hosts;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- third parties who provide our call booking service via our website; and
- credit reference agencies.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.
How long your personal data will be kept
We will only keep your personal data for as long as we need it. If you have an account, this means we keep your personal information when your account is active. We may also keep your personal data for legal or technical reasons and also fraud prevention.
When we decide how long we need to keep your personal data for, we take into account 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 we use your personal data for and whether we can achieve those purposes another way, and applicable legal requirements.
Transferring your personal data out of the UK
Your personal data may be transferred to a country outside of the UK if we use third party payment providers for example who are located outside of the UK. If we do transfer personal data outside of the UK, we will only transfer it to countries that are subject to an adequacy decision issued by the European Commission, or where the entity is bound by an appropriate personal information transfer agreement as deemed adequate by the European Commission, known as the Standard Contractual Clauses.
Your rights
You have the following rights, which you can exercise free of charge:
Access | The right to be provided with a copy of your personal data | |
Rectification | The right to require us to correct any mistakes in your personal data | |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations | |
Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data | |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations | |
To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims | |
Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
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The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by [insert details as relevant depending on consents] Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
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For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’ and provide enough information to identify yourself (eg your full name and address) and also please let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
This privacy notice was published on 03/07/2023 and last updated on 05/07/2023
We may change this privacy notice from time to time—when we do we will inform you via our website or e-mail depending on the nature of the change.
How to contact us
You can contact us by email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are at the bottom of this page
