Privacy Notice

Introduction

Welcome to Kensington Friendly Collecting Society Limited’s (“Kensington Friendly Society”) Privacy notice. You will most likely know us as “Tees Mutual” which is our trading name.

Kensington Friendly Society respects your privacy and is committed to protecting your personal data. This Privacy notice will inform you as to how we look after your personal data when you visit our website and submit a loan application (regardless of where you visit it from) or when you submit an application form with one of our agents, and tells you about your privacy rights.

Please also use the “Glossary” to understand the meaning of some of the terms used in this Privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

   This Privacy notice aims to give you information on how Kensington Friendly Society collects and processes your personal data which you may provide through our website or when you visit our office.

   Our website is not intended for children and we do not knowingly collect data relating to children.

   It is important that you read this Privacy notice together with any other Privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy notice supplements the other notices and is not intended to override them. 

   Controller

   1. Kensington Friendly Society (trading as ‘Tees Mutual’) is the data controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this Privacy notice) and is responsible for our website.

      We have appointed a Data Protection Manager, Phil Carey who is responsible for overseeing questions in relation to this Privacy notice. If you have any questions about this Privacy notice, please contact the Data Protection Manager using the details set out below.

   2. Contact details

      K Our full details are: Kensington Friendly Collecting Society Limited, 1-3 Kensington Road, Middlesbrough TS5 6AL.

      Name of the Data Protection Manager: Phil Carey (01642 850022).

      You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

   3. Changes to the Privacy notice and your duty to inform us of such changes

      This version was last updated in March 2018.

      It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

   4. Third party links

      When you use our website, it may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

   Personal data or ‘personal information’, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

   We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

   Identity Data

   includes first name, maiden name, last name or similar identifier, national insurance number, marital status, title, date of birth and gender.

   Contact Data

   includes address, email address and telephone numbers.

   Financial Data

   includes your budget for quick quotes, bank account and payment card details.

   Transaction Data

   includes details about payments to and from you and other details of services you have purchased from us.

   Marketing and Communications Data

   includes your preferences in receiving marketing from us and our third parties and your communication preferences.

   Technical Data

   includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

   Profile Data

   includes your username and password, purchases or services made by you, your interests, preferences, feedback, survey responses and details of your visits to our office.

   Usage Data

   includes information about how you use our website and services.

   Marketing and Communications Data

   includes your preferences in receiving marketing from us and our third parties and your communication preferences.

   Special Categories of Personal Data (“sensitive data”)

   as part of our application process. This may include your smoker status, details of your previous illnesses, your height and weight, physical or mental impairments or disabilities and details of medication that you are currently receiving.

   We may keep a record of any correspondence which is sent to you or received by us from you which includes some of the above Data.

   If you fail to provide personal data

   Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e to provide you with inancial services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

   We use different methods to collect data from and about you.

   You may give us your Identity, Sensitive, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

   • apply for a quote for a funeral plan, savings plan or income cover, or another service, be it with one of our agents or online;

   • create an account on our website;

   • subscribe to our service, publications or newsletter;

   • request marketing to be sent to you;

   •  enter a competition, promotion or survey; or

   • give us some feedback.

4. AUTOMATED TECHNOLOGIES OR INTERACTIONS

   When you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

5. THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES

   We may receive personal data about you from various third parties and public sources as set out below:

   Technical Data from the following parties:

   1. Analytics providers such as Google, Facebook and Twitter based outside the EU.

   When you use our website, or when you submit an application form via one of our agents in person:

   • Contact, Financial and Transaction Data from providers of technical and payment services such as third party debit card processors.

   • Identity and Contact Data from data brokers or aggregators.

   • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.

6. HOW WE USE YOUR PERSONAL DATA

   We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

   • To meet the purposes that you provided your information for (i.e. performing our contract with you, or taking steps to allow us to do so);

   • Where we need to comply with a legal or regulatory obligation or prevent fraud;

   • To notify you of any changes to our products or services or about new products or services;

   • To contact you in respect of any queries we have about any information you have provided/any response given to our application forms;

   • Where you have explicitly consented to us processing your sensitive data when completing your online application and/or have signed our consent form;

   • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, if you have asked us to provide you with information about our products and services, including those of related companies such as Careys Personal Credit (“Careys”).

   • Generally we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending you direct marketing communications via email or post. You have the right to withdraw consent to marketing at any time by contacting us at PCarey@careyskens.com.

7. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

   We have set out below, in a table format, a description of all the ways we plan to use your personal and sensitive data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

   Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

   Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
   To register you as a new customer	(a) Identity (b) Contact (c) Sensitive	(a) and (b) Performance of a contract with you (c) When you have explicitly consented to us doing so in our consent form
   To process your application for our service: (a) To perform anti-money laundering checks online (b) Manage payments, fees and charges (c) To renew insurance cover on your behalf (d) Collect and recover money owed to us (e) Provide the appropriate level of cover suitable for your circumstances	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Sensitive	(a) Performance of a contract with you (i.e. to provide you with appropriate cover and renew such cover when appropriate (ground (b) also applies here) (b) To comply with a legal obligation (to undertake money laundering checks) (c) Necessary for our legitimate interests (to renew your insurance cover if and when it is about to expire and recover debts due to us) (d) When you  have explicitly consented to us doing so
   (a) To share your personal data with CRAs before entering in to an agreement with you, PPI agencies and fraud prevention agencies detailed in section 14 of this Privacy notice. The data provided to CRAs also includes details of the payments you make under our contract and any default or failure to keep to the contractual terms.	(a) Identity	(a) Performance of a contract with you (b) Necessary for our legitimate interests to provide the correct loan in accordance with your financial circumstances, ensure repayments can be made as appropriate, to trace debtors, recover debts, prevent or detect money laundering and fraud, to manage your account(s) (c) Necessary to comply with a legal obligation to provide and support open and transparent lending in accordance with the Financial Conduct Authority and Consumer Credit Sourcebook (CONC)
   To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy notice (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
   To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
   To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
   To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. To notify you about changes to our products and services	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
   To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
   To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

8. MARKETING

   We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. This is why we provide you with the option to opt in, or opt out of our marketing services using the tick box on our website.

   For non-website users, you can opt out of our marketing by emailing PCarey@careyskens.com or by clicking ‘opt out’ in our marketing emails.

9. 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 and services may be relevant for you (we call this marketing).

   You will receive marketing communications from us if you have requested information from us or you have opted in to doing so as per the above, and you have not opted out of receiving that marketing. The marketing communications that you will receive from us will only be in relation to the services and products offered by us.

10. THIRD-PARTY MARKETING

    We will get your express opt-in consent again before we share your personal data with any company outside Kensington Friendly Society for marketing purposes and will never sell your data for marketing purposes.

11. OPTING OUT

    You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time at PCarey@careyskens.com.

    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, experience, or other transactions. 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.

12. COOKIES

    In respect of our website, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. If you would like to find our more, please see our Cookies policy.

13. 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.

14. 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 section 7 above:

    • Service providers who provide IT and system administration services to us.

    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

    • Our employees. We share our premises with Careys Personal Credit and we have the same infrastructure, staff and information processing systems. Access to your data however will be restricted to Kensington Friendly Society’s’ staff and we have security measures in place to protect your data;

    • HM Revenue & Customs, regulators such as the Financial Conduct Authority and other authorities based in the UK who require reporting of processing activities in certain circumstances.

    • Our marketing body, PG Mutual for the purposes of marketing Tees Mutual products and services to you which you have consented to receive;
       
    • 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 and sensitive data in the same way as set out in this Privacy notice.
       
    • If we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation. This includes fraud prevention and/or credit risk reduction purposes.

    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 and only permit them to process your personal data for specified purposes and in accordance with our instructions, or their legal obligations within the financial sector.

15. INTERNATIONAL TRANSFERS

    We do not transfer your personal data outside the European Economic Area (EEA).

16. 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 and to 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.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

17. 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, renewing policies on your behalf, and 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.
    
    In some circumstances you can ask us to delete your data: see 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.

18. YOUR LEGAL RIGHTS

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. In brief they are the rights to:

    	Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    	Request correction 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    	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.

    If you wish to exercise any of the rights set out above, please contact Phil Carey immediately on 01642 850022.

    1. 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.

    2. 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.

    3. 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.

19. GLOSSARY

    Term

    Definition

    “Lawful basis”

    Legitimate Interest means the interest of our business in conducting and managing Kensington Friendly Society 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 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. Express consent means processing your data only when we have your express consent to do so, in accordance with our consent form.