How do we collect your personal data?

Personal data is collected by us using the following methods:

• Direct interactions with employees and/or authorised representatives of Noonah, by post, phone, email, social media or otherwise when enquiring about a product or service offered by Noonah.
• Automated technologies or interactions with our website, by using the web enquiry form or any other automated means.
• Third parties or publicly available sources such as:Social Media, Blogs, Internet Searches, Online Advertising, CRM Systems, Suppliers and support ticket platforms.

How do we use your personal data?

We use your personal data in the following circumstances and relying on the following lawful basis for processing:

Purpose / Activity	Type(s) of data	Lawful basis for processing
Initial Contact	Identity, Contact Information, Marketing & Comms	Consent, Performance of a contract
Supplying goods or services	Identity, Financial, Contact Information, Technical	Consent, Performance of a contract
Warranty / Returns	Identity, Financial, Contact Information, Technical	Consent, Performance of a contract, to comply with legal obligation
Continuation and re-engagement of client relations	Identity, Financial, Contact Information, Technical, Marketing & Comms	Consent, Legitimate Interest, Performance of a contract
Technical Support	Identity, Contact Information, TeamViewer Access	Consent, Performance of a contract
Use of Data Analytics to improve our website, products and services, marketing and customer relationship experiences.	Technical, Location, Profile and Usage	Legitimate Interest
Transferring of information to third parties	Identity, Contact, Financial, Technical, Locations, Transaction, Personal Interest Photographic, Profile, Marketing & Comms	Legitimate Interest, Performance of a contract, Consent, to comply with legal obligation

Change of purpose

We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. 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.

Changes to our Privacy Notice

We keep our Privacy Notice under regular review and we will place any updates on this web page. This Privacy Notice was last updated on 2nd Jan 2022.

Marketing communications

You will also have the choice to opt-in to receiving other related marketing information and related products and services.

You can opt-out of receiving these types of communications at any time by contacting our Compliance team at [email protected] or by clicking on the relevant link in email communications you receive from us.

However please note that your personal information will not be passed to any third-party organisation for marketing purposes.

Data Security

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. We also limit access to your personal data to only those Noonah staff, appointed representatives, advisers, business partners and suppliers 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Cookies

When using Noonah websites, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Website Third-party links

Noonah’s websites may include links to third-party websites, 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 and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Sharing of personal data outside of the European Economic Area

Some of our external suppliers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Where we use providers based in the US , 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 the Europe and the US.

If we transfer data to an external supplier outside of the EEA whom is not part of the US Privacy Shield we will endeavour to ensure that your data is processed in accordance with the GDPR.

We may also use specific contracts approved by the European Commission that provide the same level of protection for personal data as it has in the EEA.

Who we disclose personal data to

Your personal data may be shared with third parties for the following purposes:

Type of recipient	Reason
External Suppliers & Contractors	Specialist IT system providers to facilitate the customer relationship management, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards. It may also be necessary to share your personal; information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Noonah.
Outsourced Support Provider	In order to provide out of hours technical support services in relation to our products and services we use third party suppliers and your data may be transferred to them for this purpose.
Regulators	Sharing information may be necessary to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering Legislation and otherwise co-operate with law enforcement, legal proceedings and regulatory authorities.
Others	Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge them. 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.

These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with Noonah instructions.

How long is your personal data retained?

We only retain your personal data for as long as necessary. The table below outlines how long data is retained, and depends on the reason the personal data is used for:

Purpose of processing	Retention Period
Purchase of goods / services contract	7 Years from the date of the original contract for legal obligations and defending potential legal claims.
Data relating to enquiries made that have not formed part of a formal contract obtained directly and from third parties.	2 Years in order for us to continue to contact the client between the period of initial enquiry to the point of forming a contract or the client requesting their data is deleted – whichever is the sooner.
Data relating to clients who have opted in for marketing	Indefinitely, or until such time client withdraws consent.
Data relating to existing customers	7 Years from the date of the original contract for legal obligations and defending potential legal claims and also to maintain customer relationships.

Any categories of personal data not referenced specifically above, will be retained for as long as necessary taking into account the lawful basis for collecting the personal data initially, any ongoing obligations imposed on Noonah and the fundamental rights and freedoms of the data subject.

Your legal rights regarding your personal data after these retention periods if there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.

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. This enables you to have any incomplete or inaccurate data 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 personal data where there is no good reason for us continuing to process it. You can also to ask us to delete your personal data where you have successfully objected to the 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 delete the data 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.

Questions

If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact Noonah by emailing [email protected] or by writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.

What if I am still not satisfied?

If you are not satisfied with how the Noonah has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.