My Pin Address

Privacy

1) HOW YOUR PERSONAL INFORMATION IS USED BY my pin address

Your information will be held by my pin address. This privacy notice is to let you know how my pin address promises to look after your personal information.

This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

2) OUR PRIVACY PROMISE

We Promise:

To keep your data safe and private
Not to sell your data
To give you ways to manage and review your marketing choices at any time

3) HOW THE LAW PROTECTS YOU

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside my pin address. The law says we must have one or more of these reasons:

To fulfil a contract we have with you, or
When it is our legal duty, or
When it is in our legitimate interest, or
When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

What We Use Your Personal Information For	Our Reasons	Our Legitimate Interests
To deliver of our products and services	Fulfilling contracts	Being efficient about how we fulfil our contractual duties
To manage our relationship with you or your business	Fulfilling contracts	Being efficient about how we fulfil our contractual duties
To provide advice or guidance about our products and services	Our legitimate interests	Developing products and services, and what we charge for them.
To develop new ways to meet our customers’ needs and to grow our business	Our legitimate interests	Developing products and services, and what we charge for them.
To manage how we work with other companies that provide services to us and our customers	Fulfilling contracts	Being efficient about how we fulfil our contractual duties
To respond to complaints and seek to resolve them	Fulfilling contracts	Being efficient about how we fulfil our legal and contractual duties
To manage risk for us and our customers	Fulfilling contracts	Being efficient about how we fulfil our legal and contractual duties
To make and manage customer payments	Fulfilling contracts	Being efficient about how we fulfil our contractual duties
To manage fees, charges and interest due on customer accounts	Fulfilling contracts	Being efficient about how we fulfil our contractual duties
To collect and recover money that is owed to us	Fulfilling contracts	Being efficient about how we fulfil our contractual duties
To detect, investigate, report, and seek to prevent financial crime	Our legal duty	Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect
To obey laws and regulations that apply to us	Our legal duty	Complying with regulations that apply to us
To exercise our rights set out in agreements or contracts	Fulfilling contracts	Being efficient about how we fulfil our legal and contractual duties
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit	Our legitimate interests and legal duty	Being efficient about how we fulfil our legal and contractual duties and complying with regulations that apply to us

4) GROUPS OF PERSONAL INFORMATION

We use many different kinds of personal information, and group them together like this:

Type of Personal Information	Description
Financial	Your financial position, status and history
Contact	Where you live and how to contact you
Socio-Demographic	This includes details about your work or profession and nationality
Transactional	Details about payments to and from your accounts with us
Contractual	Details about the products or services we provide to you
Locational	Data we get about where you are, such as may come from your mobile phone, the address where you connect a computer to the internet, or a shop where you buy something with your card
Behavioural	Details about how you use our products and services
Technical	Details on the devices and technology you use
Communications	What we learn about you from letters, emails, and conversations between us
Usage Data	Other data about how you use our products and services
Consents	Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you and whether you get paper statements

5) WHERE WE COLLECT YOUR PERSONAL INFORMATION FROM

We may collect personal information about you (or your business) from these sources:

Data you give to us:

When you apply for our products and services
When you talk to us on the phone or in person
When you use our website
In emails and letters
In insurance claims or other documents
In account reviews and meetings
In customer surveys

Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:

Payment and transaction data.
Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones.

Data from third parties we work with:

Credit reference agencies
Insurers
Cloud Service Providers
Fraud prevention agencies
Payroll service providers
Public information sources such as Companies House
Official Regulators (Ofcom etc)
Agents working on our behalf
Market researchers
Government and law enforcement agencies

6) WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may share your personal information with affiliates, vendors, subcontractors or other service-providers carrying out services on your behalf as well as the following organisations:

HM Revenue & Customs, regulators and other authorities
Credit reference agencies
Fraud prevention agencies
Any party linked with you or your business’s product or service
Companies we have a joint venture or agreement to co-operate with
Companies that we introduce you to
Market researchers
Companies you ask us to share your data with

We may need to share your personal information with other organisations to provide you with the product or service you have chosen:

If you use direct debits, we will share your data with the Direct Debit scheme.

We may also share your personal information if the make-up of my pin address changes in the future:

We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

7) HOW WE USE YOUR INFORMATION TO MAKE AUTOMATED DECISIONS

We sometimes use systems to make automated decisions based on personal information we have or are allowed to collect from others, about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.

Here are the types of automated decision we make:

Pricing

We may decide what to charge for some products and services based on what we know about there usage.

Tailoring Products and Services

We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.

Detecting Fraud

We may detect that an account is being used in ways that fraudsters work, or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.

Opening Accounts

When you open an account with us, we check that the product or service is relevant for your business, based on what we know. We also check that you or your business meets the conditions needed to open the account. This may include checking your businesses financial position.

Your Rights

As a person you have rights over automated decisions.

You can ask that we do not make our decision based on the automated score alone.
You can object to an automated decision and ask that a person reviews it.

If you want to know more about these rights, please contact us.

8) VISITORS TO OUR WEBSITES

When someone visits www.my pin address.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

9) SENDING DATA OUTSIDE OF THE EEA

my pin address uses a proprietary Customer Relationship Management (CRM) solution designed and managed by Optimal Solutions. This company is based outside of the European Economic Area (‘EEA’). However, the data held within this solution is hosted within the United Kingdom and my pin address does not allow Optimal Solutions access to your personal or business data.

10) IF YOU CHOOSE NOT TO GIVE PERSONAL INFORMATION

We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us. Any data collection that is optional would be made clear at the point of collection.

11) JOB APPLICANTS, CURRENT AND FORMER my pin address EMPLOYEES

my pin address is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at admin@my pin address.co.uk.

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary. We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for. We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.

We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our management team will have access to all of this information. You will also be asked to provide equal opportunities information. This is not mandatory information, if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our management team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
You will be asked to complete a criminal records declaration to declare any unspent convictions.
We will contact your referees, using the details you provide in your application, directly to obtain references

If we make a final offer, we will also ask you for the following:

Bank details – to process salary payments
Emergency contact details – so we know who to contact in case you have an emergency at work

Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

12) MARKETING

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’. The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with. We study this 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 can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

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

Whatever you choose, you'll still receive statements, and other important information such as changes to your existing products and services.

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can update your choices at any time by contacting us.

13) HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will keep your personal information for as long as you are a customer of my pin address.

After you stop being a customer, we may keep your data for up to 15 years for one of these reasons:

To respond to any questions, complaints or potential legal disputes.
To show that we treated you fairly.
To maintain records according to rules or legislation that apply to us.

We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.

14) HOW TO GET A COPY OF YOUR PERSONAL INFORMATION

You can access a copy of your personal information by writing to us at this address:

FAO: Managing Director

my pin address

283 Green Lanes
London
England
N13 4XS

15) FUTURE FORMATS FOR SHARED DATA

The General Data Protection Regulation (GDPR) came into force at 5pm on Friday 25th May 2018.

From this point onwards, you will have the right to get your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information in this format to other organisations.

16) LETTING US KNOW YOUR DATA IS INCORRECT.

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.

If you do, we will take reasonable steps to check its accuracy and correct it.

17) WHAT IF YOU WANT US TO STOP PROCESSING YOUR INFORMATION?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:

It is not accurate.
It has been used unlawfully but you don’t want us to delete it.
It not relevant any more, but you want us to keep it for use in legal claims.
You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.

18) HOW TO WITHDRAW CONSENT

You can withdraw your consent at any time. Please contact us if you want to do so.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

19) HOW TO COMPLAIN

Please let us know if you are unhappy with how we have used your personal information.

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

my pin address call recording policy

1. PURPOSE

In order to maintain our terms and conditions and standards and protect the interests of both the public and our employees, my pin address may record conversations or exchanges. We shall ensure that the use of these recordings is fair and that we comply with the requirements of the relevant legislation. This includes:

The Data Protection Act 2018;
The European General Data Protection Regulation (GDPR);
The Human Rights Act 1998;
The Regulation of Investigatory Powers Act 2000;
The Telecommunications (Lawful Business Practice) (Interception of
Communications Regulations) 2000;
Privacy and Electronic Communications Regulations 2003

2. SCOPE

This policy applies to all Personal Data that my pin address collects, holds and processes as part of the recording of any telephone calls relating to conversations or exchanges.

This policy applies to all of my pin address’s legal entities and operations and must be complied with by the Personnel working for my pin address at all levels and grades, including Senior Managers, Directors and employees (whether permanent, fixed-term or temporary) wherever they are located.

It is the responsibility of all my pin address Personnel to have knowledge of all relevant my pin address information security and privacy policies and processes. Additionally, all consultants and suppliers must comply with this policy if they act on behalf of my pin address or collaborate with my pin address and have access to Personal Data.

3. RELATED POLICIES

This Call Recording Policy should be reviewed in conjunction with my pin address’s Privacy Statement and Data Protection and Privacy Policy.

4. CALL RECORDING OVERVIEW

What Calls are Recorded?

my pin address may record any conversations or exchanges that may be used to help us uphold our standards, terms and conditions.

NOTE: my pin address does not record the content of any telephone conversations initiated as internal calls between extension users as well as calls outside of their telephony system, including conversations made between mobile telephones.

Purposes of Call Recording

my pin address may record conversations in order to:

Establish the facts of a complaint issued by a member of the public or user in relation to any content published on my pin address
Provide, where necessary, evidence in legal disputes or regulatory hearings

Processing of Information

my pin address aims to ensure that individuals are aware that their data is being processed, and that they understand how their data is being used and how to exercise their rights. Personal data collected in the course of recording activities will be processed fairly and lawfully in accordance with the current Data Protection Act and the General Data Protection Regulation.

Data collected will be:

Adequate, relevant and not excessive
Used for the purpose(s) stated in this policy only and not used for any other purposes
Accessible only to my pin address’s Team after securing permission from the Managing Director
Treated confidentially
Stored securely
This data will be retained in line with my pin address’s data retention and destruction policy.

Advising Callers that Calls are being Recorded

Where call recording facilities are being used, we will inform the caller that their call is being recorded and the reasons why so that they have the opportunity to consent by continuing with the call or hanging up.

Procedures for Managing and Releasing Call Recordings

my pin address will ensure that the following procedures are enforced for the Management and Releasing of any call recordings:

The recordings shall be stored securely, with access to the recordings controlled and managed by the Data Protection Officer.
Access to call recordings will be given only to my pin address’s Editorial Team
Individuals requesting access to their call recordings will be dealt with as a Subject Access Requests. Please refer to my pin address’s Data Protection and Privacy Policy for further information regarding Subject Access Requests.
Browsing of recordings for no valid reason is not permitted.
Every individual has the right to access the information that we hold about them. This includes recorded telephone calls. Therefore, the recordings will be stored in such a way to enable the Data Protection Officer to retrieve information relating to one or more individuals as easily as possible.

5. AUDITING

This Information Security Policy is audited on an annual frequency. The Managing Director is responsible for addressing non-conformances within this Information Security Policy. Enforcement of the Policy is achieved via organisational, departmental, or product specific security profiles.

6. VIOLATION AND ENFORCEMENT

Disclosure of Personal Data without authority is a serious breach of my pin address’s duty to maintain the security of Personal Data. All violations of this Policy will be reported to the Managing Director as a Security Incident. This should be completed as soon as the non-conformance is identified either via an email or by raising an Information Security Incident directly to the DPO.

Violations of this Policy may result in immediate withdrawal or suspension of system and network privileges and/or disciplinary action in accordance with my pin address’s disciplinary procedures – up to and including termination. my pin address may need to advise law enforcement when a criminal offense may have been committed.