David Ashley – Privacy Policy

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Please note that personal information we are holding about you may be shared with and processed by:

• regulators or other third parties for the purposes of monitoring and/or enforcing our compliance with any legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
• credit reference and fraud prevention agencies;
• any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
• other parties and/or their professional advisers involved in a matter where required as part of the conduct of the services;
• our own professional advisers and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
• credit financing companies (such as Klarna) if financing is requested by you as part of a purchase of goods and/or services from us;
• our service providers and agents (including their subcontractors) or third parties which process information on our behalf (e.g. internet service and platform providers, our bank, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested; and
• another organisation to whom we may transfer our agreement with you or if we sell or buy (or negotiate to sell or buy) our business or any of our assets (provided that adequate protections and safeguards are in place).

Please note that we include links within our website to third party social media providers such as Facebook and Twitter, but we will not share your information with such providers without your consent.

We will not transfer personal data relating to you to a country which is outside the European Economic Area (EEA) unless:

• the country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;
• appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 (for example using the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA); or
• one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer. These include (in summary):
• the transfer is necessary to perform, or to form, a contract to which we are a party:
• the transfer is necessary for the establishment, exercise or defence of legal claims;
• you have provided your explicit consent to the transfer; or
• the transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.

• Unless we are required or permitted by law to hold on to your data for longer specific retention period (for example, by rules imposed by the Financial Conduct Authority), we will only hold your personal information on our systems for a period of 6 years from your last transaction with us.
• In some circumstances we will 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.
• Where we no longer need your personal information, we will dispose of it in a secure manner.

• You have certain rights under existing data protection laws, including the right to (upon written request) access a copy of your personal data that we are processing. From 25 May 2018, in accordance with the GDPR:
• you will have the following rights:
• in certain circumstances, you will also have the following rights:
• You have the right to unsubscribe from our marketing communications at any time by following the link in the footer of the last email you received from one of our brands (“Unsubscribe”) or by sending your request with detailed instructions to us (see contact details above in the “Data Controller details” section.
• Please note that if you withdraw your consent to the use of your personal information for purposes set out in our Privacy Policy, we may not be able to carry out our contractual obligations to you or provide you with access to all or certain parts of our services.
• If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: www.ico.org.uk.

We do not make decisions based solely on automated data processing, including profiling.

We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:

• where appropriate, data is encrypted when transiting on our system or stored on our databases;
• we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and
• we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.

However, while we will do our best to protect your personal information, we cannot guarantee the security of your information which is transmitted via an internet or similar connection. It is important that all details of any username, password and/or other identification information created to access our servers are kept confidential by you and should not be disclosed to or shared with anyone.

We may amend this Privacy Policy from time to time, for example to keep it up to date, to implement minor technical adjustments and improvements or to comply with legal requirements. We will always update this Privacy Policy on our website, so please try to read it when you visit the website (the “last updated” reference tells you when we last updated our Privacy Policy).

Last updated August 2020