Centurion Estate Planning Ltd
Laurel Hill Business Park
- About our site
- How our site works
- About us
- What we don’t do with your data
- What data we collect, and how
- How we use your data
- Transferring your data
- Storing your data
- Legal grounds
- Your rights
- Contacting us
- Changes to this notice
ABOUT OUR SITE
Our site enables people to request a quote or information for the product or service shown or selected on this site (the “Product”).
The service that our site provides is to connect people who are looking to purchase the Product with relevant providers of the Product (“Service Providers”).
HOW OUR SITE WORKS
If you’d like to request and receive quotes or information for the Product (“Quotes”), please complete and submit our webform.
Once we’ve received your request, we’ll contact you directly with your requested Quotes or product information
We have a really clear consent statement as displayed on all web forms. This statement sets out the Service Providers that will contact you
Centurion Estate Planning Ltd(“ltd”, “we”, “us”, “our”) is a company registered in Scotland company number: SC670359 whose registered office address is at C/O Donoghue & Co. Ltd, 19a Wellside Place, Falkirk, Scotland, FK1 5RL.
For the purposes of the General Data Protection Regulation (the “GDPR”), Centurion Estate Planning Ltd is the controller in relation to your data. We are registered as a controller with the UK Information Commissioner’s Office (ICO) under registration number ZA779853. You can confirm our registration here: www.ico.org.uk
WHAT WE DON’T DO WITH YOUR DATA
- We don’t share it with anyone else (other than relevant Service Providers)
- We don’t use it for any purpose (including retargeting, commingling across multiple advertisers’ campaigns or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis, and only to assess the performance and effectiveness of our advertising campaigns.
- We don’t use it to build, append to, edit, influence or augment user profiles, including profiles associated with any mobile device identifier or other unique identifiers that identify any particular user, browser, computer or device.
- We don’t transfer it (including any anonymous, aggregate or derived data) to any advertising network, advert exchange, data broker, or other advertising or monetisation-related service.
WHAT DATA WE COLLECT, AND HOW
If you complete our webform in order to request Quotes or product information, it will ask you for your contact details, such as list below,
- Your name,
- email address,
- telephone number,
- postal address,
- desired service.
Our webform will also ask for information regarding your product requirements (where relevant).
We may sporadically change our webforms, as a result of this they may ask you for other information. We will always make it clear in the webform what information we’re requesting, and we only request information that is relevant to your request, and the service that we’re providing.
We also store and share Internet Protocol (IP) addresses, as explained below. Every computer or device has an IP address – a unique number – which enables it to communicate with other computers and devices over the Internet.
We may monitor and/or record these calls for the purposes of quality control and staff training. Also occasionally, we may need to provide Service Providers with limited access to such recordings in order to resolve disputes.
HOW WE USE YOUR DATA
We use your data (described above) in the following ways.
TO CONNECT YOU WITH RELEVANT SERVICE PROVIDERS
As explained above, if you submit our webform, we’ll pass your request to one or more relevant Service Providers. We will do this in a secure way. For example, using HTTP Secure (HTTPS), which means the data is encrypted. The Service Providers then contact you directly with your quotes. They may contact you by telephone, text/SMS or email.
Before we pass your request to any Service Providers, our service may involve an element of automated decision-making. Our technology platform may automatically assess your Product requirements and pass your request to such Service Providers that would like to receive requests for Quotes at the time your request is made.
We store IP addresses in order to stop unwanted traffic (i.e. spam) to our site. For example, if we become aware that spam is coming from a particular IP address (i.e. computer or location), we can block that IP address. From time to time, we also share IP addresses with Service Providers to enable Service Providers to verify that requests for Quotes have come from a particular country.
You will always be given an opportunity to opt out of such messages before we send them, and we will not send such messages if you have opted out.
RECEIVING DATA FROM SERVICE PROVIDERS
From time to time, Service Providers may return data to us. They may do this if they have a query regarding a request for Quotes that we have sent to them in order to enable us to resolve the query. They may also return data to us, together with confirmation on whether or not a product has been purchased, in order to enable us to improve our marketing. We may also use such data to create custom and lookalike/similar audiences, as explained above.
WORKING WITH SUPPLIERS
We work with a number of suppliers, who process data on our behalf. These include, email service providers and telephone number validation services. We have appropriate contracts in place with such suppliers to ensure the protection and confidentiality of data.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. At the bottom of this policy, we have included a table, setting out what cookies we use, and the purposes for which we use them.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
STORING YOUR DATA
We have a data retention policy, which clearly sets out how long we keep data for, and for what reasons.
We will keep your data only for as long as is necessary to fulfil the purpose/s for which it was collected in the first place, i.e. as set out in this notice.
- We will keep your request for Quotes for 6 months after you make the request to enable us to resolve any queries from Service Providers, should they arise.
- If you haven’t opted out of receiving marketing from us, we will keep your details, and send you emails, until such time as you don’t engage with our emails for a period of 6 consecutive months.
Following the periods set out above, we will not use the data, save that we will hash/anonymise the same, and retain it for a further 3 years for compliance purposes.
This notice sets out (above) how we use your data. Under the GDPR, controllers must have a valid lawful basis for each processing activity that they undertake. This section sets out our lawful basis for each activity.
|Activity||Lawful Basis under the GDPR||Your Rights|
|To service your enquiry||Consent||To withdraw your consent, as explained below|
|Using and sharing IP addresses||Legitimate interests||You have the right to object to processing based on legitimate interests|
|Receiving data from Service Providers||Legitimate interests||You have the right to object to processing based on legitimate interests|
Under the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), we send such emails on the basis of the existing customer (soft opt-in) exemption.
In each case where we have identified legitimate interests as the legal basis for our processing, we have conducted a legitimate interest’s assessment.
Under the GDPR, you have a number of rights. In relation to our site, and the service that we provide, those rights are set out in the table above. We further explain these rights, and your other rights, below.
RIGHT OF ACCESS
You have the right at any time to ask us for a copy of the personal information that we hold about you, and to check that we are lawfully processing it.
RIGHT OF RECTIFICATION
If personal information that we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.
RIGHT OF ERASURE
In certain circumstances, you have the right to request that personal information we hold about you is erased (e.g. if the information is no longer necessary for the purposes for which it was collected or processed).
RIGHT TO OBJECT TO OR RESTRICT PROCESSING
In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests, and there are no compelling legitimate grounds for our processing which override your rights and interests.
RIGHT OF DATA PORTABILITY
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You can exercise this right by contacting us in any of below ways.
Email – firstname.lastname@example.org
Phone – 0330 133 2206
In Writing – Centurion Estate Planning Ltd, Springfield House, Laurel Hill Business Park, Stirling, FK7 9JQ.
EXERCISING YOUR RIGHTS
If you wish to exercise any of your other rights under the GDPR, please email us at email@example.com. Alternatively, you can write to us at the address set out above, or inform us if you speak with us on the phone.
Our lead supervisory authority for the processing set out in this notice is the UK Information Commissioner’s Office (ICO). If you are unhappy with how we have processed your data, you have the right to make a complaint to the ICO.
If you have any questions regarding this notice, or any questions relating to data protection or privacy, you can contact us at firstname.lastname@example.org
Alternatively, you can write to us at the address set out above.
CHANGES TO THIS NOTICE
From time to time, we may update this notice.
Last reviewed: 14th September 2020