Marketing

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage 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).

You will receive marketing communications from us if you have requested
information from us or placed a request with us or purchased goods or
services from us or if you provided us with your details when you entered
a competition or registered for a promotion and, in each case, you have not
opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data
with any company outside the Invilia group of companies for marketing
purposes unless we have your consent or are otherwise permitted to by
law.

Opting out

You can ask us or third parties to stop sending you marketing messages at
any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not
apply to personal data provided to us as a result of a product/service
purchase, product/service experience or other transactions.

Change of purpose

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.

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.
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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below
for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• 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 with 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.

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 unless
its related to allowing us to provide products and services to you and only
permit them to process your personal data for specified purposes and in
accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within the Invilia group. This may involve
transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European
Economic Area (EEA) so their processing of your personal data will involve
a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a
similar degree of protection is afforded to it by ensuring at least one of the
following safeguards is implemented:

• We will only transfer your personal data to countries that have been
deemed to provide an adequate level of protection for personal data
by the European Commission.

• Where we use certain service providers, we may use specific
contracts approved by the European Commission which give personal
data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism
used by us when transferring your personal data out of the EEA.

7. 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. 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. In the event of a data breach will notify you and any
applicable regulator where we are legally required to do so.

8. DATA RETENTION

How long will you use my personal data for?

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.

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.

By law we have to keep basic information about our customers (including
Contact, Identity, Financial and Transaction Data) for seven years after
they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request
erasure below for further information.

In some circumstances we may anonymise your personal data (so that it
can no longer be associated with you) for research or statistical purposes
in which case we may use this information indefinitely without further notice
to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in
relation to your personal data. To find out more about these rights, please
refer to paragraph 10 below:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

10. GLOSSARY

Lawful Basis

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).

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.

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.

Third Parties

Internal Third Parties

Other companies in the Invilia group acting as joint controllers or
processors and who may be based in the other jurisdictions:

• services pursuant to the contract we are about to enter into or have
entered into with you.
• IT and system administration services and undertake leadership
reporting.

External Third Parties

• partners acting as joint controllers or processors who may provide
services pursuant to the contract we are about to enter into or have
entered into with you.
• Service providers acting as processors who provide IT and system
administration services.
• Professional advisers acting as processors or joint controllers
including lawyers, bankers, auditors and insurers who provide
consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as
processors or joint controllers based in the United Kingdom who
require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

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.

Request rectification 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. 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). In some cases, we may
demonstrate that we have compelling legitimate grounds to process your
information.

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.