Filura Limited Customer Privacy Notice

Contact details

Email: robert.cass@filura.com

What information we collect, use, and why

To provide and improve products and services for clients

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Addresses
• Gender
• Occupation
• Date of birth
• Marital status
• Third party information (such as family members or other relevant parties)
• Financial data (including income and expenditure)
• Usage data (including information about how you interact with and use our website, products and services)
• Employment details (including salary, sick pay and length of service)
• Health information (such as medical records or health conditions)
• Information relating to compliments or complaints
• Records of meetings and decisions
• Account access information
• Website user information

We also collect or use the following special category information to provide and improve products and services for clients. This information is subject to additional protection due to its sensitive nature:

• Health information

For the operation of client or customer accounts

We collect or use the following personal information for the operation of client or customer accounts:

• Names and contact details
• Addresses
• Purchase or service history
• Account information, including registration details
• Information used for security purposes
• Marketing preferences
• Technical data, including information about browser and operating systems

We also collect or use the following special category information for the operation of client or customer accounts. This information is subject to additional protection due to its sensitive nature:

• Health information

For the prevention, detection, investigation or prosecution of crimes

We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:

• Names and contact information

For information updates or marketing purposes

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details
• Addresses
• Profile information
• Marketing preferences
• Website and app user journey information
• IP addresses

For research or archiving purposes

We collect or use the following personal information for research or archiving purposes:

• Names and contact details
• Addresses
• Website and app user journey information
• IP addresses

To comply with legal requirements

We collect or use the following personal information to comply with legal requirements:

• Name
• Contact information
• Identification documents
• Any other personal information required to comply with legal obligations

We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:

• Health information

To protect client welfare

We collect or use the following personal information to protect client welfare:

• Names and contact information
• Client account information
• Health and wellbeing information

We also collect or use the following special category information to protect client welfare. This information is subject to additional protection due to its sensitive nature:

• Health information

For dealing with queries, complaints or claims

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Addresses
• Account information
• Relevant information from previous investigations
• Customer or client accounts and records
• Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO's website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO's website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure – You have the right to ask us to delete your personal information.
• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information.
• Your right to object to processing – You have the right to object to the processing of your personal data.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Providing and improving products and services for clients:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Operation of client or customer accounts:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Prevention, detection, investigation or prosecution of crimes:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Information updates or marketing purposes:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You do have the right to withdraw your consent at any time.

Research or archiving purposes:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You do have the right to withdraw your consent at any time.

Complying with legal requirements:

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Protecting client welfare:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Dealing with queries, complaints or claims:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. You do have the right to withdraw your consent at any time.

Where we get personal information from

Directly from you.

How long we keep information

We will keep your personal information for as long as is necessary to provide you with our services, to comply with our legal obligations, and to resolve any disputes. When your information is no longer needed, we will securely delete or anonymise it.

Who we share information with

We may share your personal information with the following parties:

• Suppliers and service providers

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the ICO.

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint