PRIVACY AND COOKIES POLICY
 
We are Pensions for Purpose Limited, a company registered in England and Wales with company number 13092445 whose registered office is c/o Freeths LLP, Routeco Business Park, Davy Avenue, Knowlhill, Milton Keynes MK5 8HJ. We act as data controller in respect of all personal data we collect via our website, and about our members.

You can contact us by writing to us as the above address, by calling us on 01234 388845 or emailing us at [email protected].

We are committed to protecting and respecting your privacy.

This policy and any other documents referred to on it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data, how we will treat it and the cookies that we use. 

INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:

• Information you give us. This is information about you that you give us by filling in forms on our site, by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service and when you report a problem with our site. The information you give us may include your name, address, e-mail address, phone number, employer and job title.
• Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

Information you give to us. We will use this information to:

• carry out our contracts with you, including by providing you with the information, products or services that you request and notifying you about important changes to our service (e.g. changes to member benefits);
• with your consent, to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing Member we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which are on the Site; and
• to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information (on the basis of our legitimate interest in optimising our website and your user experience, unless otherwise stated):

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others;
• with your consent, to carry out analytics on the way in which you use our website; and
• with your consent, to make suggestions and recommendations to you and other users of our site about services that may interest you or them.

We occasionally receive contact details (email, phone number) from consultants engaged outside of the UK, who refer leads to us. Such leads are businesses, not consumers. Where we use your contact details, we do so on the basis of our legitimate interest in growing our reach abroad, and you can follow the instructions contained in each email we send you to opt out.

Where we use your personal data in order to carry out our contract with you, we would not be able to offer the relevant service or membership to you without doing so.

DISCLOSURE OF YOUR INFORMATION

You agree that we have the right to share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 where necessary in order to provide our service to you (for instance where your personal data is stored shared IT systems).

• Selected third parties (as set out below), namely business partners, suppliers and sub-contractors where they are acting solely on our behalf (known as data processors), including:

• Capsule CRM, who provide our CRM system;
• Material Impact, who provide analytical services to us;
• Microsoft, who provide email and collaboration technology;
• Xero, who provide our finance system;
• Mailchimp, who send emails on our behalf; and
• Backbone IT, our website designers.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets for the purposes of  carrying out due diligence.
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, in relation to a dispute with you, or for purposes of fraud prevention or carrying out credit checks.

Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.

WHERE WE STORE YOUR PERSONAL DATA

We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and deal with payment. Where we do so, we will do it in compliance with data protection law.

All information you provide to us is stored on our host providers' secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We only keep your personal data for as long as we need to in order to use it as described above, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.

YOUR RIGHTS

If you change your mind and decide that you no longer want us to process your personal data for marketing purposes please contact us.  

Under the GDPR, you have the right to:

• request access to, or correction of, your personal data held by us at no cost to you;
• request that we delete your personal data, but only in certain circumstances;
• request that your personal data be transferred to another person (data portability);
• be informed of what data processing is taking place;
• restrict processing;
• to object to processing of your personal data; and
• complain to a supervisory authority, which in the case of the UK is the Information Commissioner’s office (https://ico.org.uk/).

RELATIONSHIP WITH OTHER WEBSITES

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and Members. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

COOKIES POLICY

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We only use these where your consent to us doing so.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you and remember your preferences (for example, your choice of language or region).  We only use these where your consent to us doing so.

We place the following cookies on our website:

Cookie	Type (see above)	Purpose
PHPSESSID	Strictly necessary.	Session cookie, used to allow you to login to our site etc.
_ga, _gid, _gat_gtag_UA_107708330_1	Analytical cookie	Used by our analytics provider, Google, to record details about your usage of our site.
GatedAccess	Functionality cookie	User cookie, used to avoid users having to repeatedly fill in a form they have already submitted.
tvGatedAccess	Functionality cookie	User cookie, used to avoid users having to repeatedly fill in a form they have already submitted.

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can prevent the setting of cookies by adjusting the settings on your browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the site. For more information on how to block cookies using your browser or device settings, please see the ICO’s cookie guidance for individuals available at https://ico.org.uk/your-data-matters/online/cookies .

Except for essential cookies, all cookies will expire after 30 days.

CHANGES TO THIS POLICY

Any changes we make to our privacy and cookies policy in the future will be posted on this page.