Privacy Policy

The privacy and security of your personal information is important to us and we are committed to protecting it. It is important you read this privacy notice carefully because it explains how we collect and process personal data about you and why we are using your data.  This privacy notice also sets out your privacy rights and how the data protection law protects you.

Who we are and contact details

Fridgexpress (UK) Limited (“we”, “us” or “our” in this privacy notice) is the “controller” of your personal data which means that we are responsible for deciding how we hold and use personal data about you.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at The Acre, Lawford Heath Lane, Rugby, CV23 9EU or by email dpo@zigup.com.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy notice under regular review and we may need to make changes to it from time to time to take account of changes in law or the needs of our business. Please refer back to this page regularly to see any changes or updates to this privacy notice.

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, this includes, but is not limited to any change of name, address or contact details.

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 will collect certain personal data from you when you use our website, when you make contact with us about any of our services, when signing up as a customer and in order to manage your services.

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

• Contact Data includes your name, email and postal address, telephone number and any other relevant information we need in order to contact or identify you.
• Financial Data includes bank account and payment details relating to products and services you receive from us.
• Transaction Data includes details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address which is a unique number identifying your computer, including information to identify your browser, device and network you are using.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing and your communication preferences.

We do not request 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). We do not collect any information about criminal convictions and offences from you.

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 but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, via our website or otherwise. This includes personal data you provide when you:

• • apply for our services;
  • make an enquiry via our website;
  • request marketing to be sent to you;
  • give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
• Telephone calls. We record telephone calls for training and monitoring purposes.
• Usage Data includes information about how you interact with and use our website, products and services.
• Security information.  From CCTV recording equipment in and around our premises for monitoring and security.

We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

The legal basis for processing your personal data

We will only use your personal data when the law allows us to or where you have provided your consent. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Where we need to comply with a legal obligation including sharing information with government and regulatory authorities, when required by law or in response to legal process, obligation or request.

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.  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.

Marketing 

We will provide you with choices regarding certain personal data uses, particularly around marketing material.  You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.  We will request your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out of marketing messages

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you by contacting us at any time by post, telephone or email to dpo@zigup.com.

Third party websites and hyperlinks

Our website may contain links to websites operated by third parties.  The responsibility for the operation and content of those websites rests solely with the company controlling the third party website and will be governed by separate terms and conditions.  We do not accept any responsibility or liability for the content of any linked websites.

Cookies and similar technologies

You can set your browser to refuse browser cookies (other than those which are strictly necessary), or to alert you when websites set or access cookies. Our website provides the ability for you to confirm or change your performance and tracking cookie preferences by clicking on the “manage cookies” option displayed on the cookie banner on the landing page of our website or by returning to the cookie policy page on our website. Further information identifying the name of, uses of information collected by, and expiry dates of the cookies used by our website, together with further information to explain how to change your cookie settings can be found on our cookie policy page.

Analytics

We work with third party advertising partners, including Google, to reach individuals with more relevant content on and off our website and usage information related to our website and our ads and content. We use Google Analytics to evaluate the use of our website and services.  You can find more information on Google Analytics here.  This information is only processed in a way that does not directly identify anyone.  Google has developed a Google Analytics opt out browser add on for websites and you can find more information here  We use Google AdWords remarketing services to advertise on third party websites (including Google) to previous visitors to our site.  This could be in the form of an advertisement on the Google display network.  You can find more information about Google’s uses of information here

Analytics providers may use cookies and other similar technologies to perform their services and may combine the information they collect about you on our Sites with other information they have collected for their own purposes, this policy does not cover the use of data by third parties.

Disclosures of your personal data

Where necessary, we may  share your personal data with the following third parties or categories of third parties:

• Other companies within our group of companies.
• Zigup Plc, a group company which provides a range of group operational support services to us, including HR, IT, legal, finance and taxation, risk and compliance advice and assistance.
• Business partners, IT and software providers, agents and carefully appointed third parties providing a service to us on our behalf to help us run our business.
• Other organisations where we have a duty or are permitted to disclose your personal information by law (for example if we receive a valid request from an official organisation including but not limited to HMRC, a police force, council or local authority,  in the interests of preventing or detecting crime, checking financial sanctions lists, for the purposes of fraud protection or credit and other risk reduction).
• Other third parties or individuals if you have given us permission to do so or they are acting on your behalf.
• legal, financial and other professional advisors, debt collection agencies or other third party organisations to assist with the recovery of amounts owed to us by you or the organisation you represent under any agreement between you and us and other organisations that have a specific role in law such as statutory and regulatory bodies
• Another company if our business or part of it is bought or taken over by that company or during confidential discussions about a sale or take over.  We will ensure the information is protected by confidentiality agreements.
• There may be occasions when we must share information (including with regulators) about you so that we comply with a legal obligation, to enforce or apply our website terms of use, other agreements or to protect the rights, property or safety of ourselves, our customers or someone else.
• In order to process your application we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you such as your financial history.  We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.  We will also continue to exchange information about you with CRAs on an ongoing basis, including your settled accounts and any debts not fully repaid on time.  CRAs will share your information with other organisations.  The identity of the CRA we use and the way in which it uses and shares personal information are explained in more detail at http://www.experian.co.uk/crain/index.html

Unless we are required to disclose your information by law, we will not share your personal data without safeguards being in place.  We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We have contracts in place with our third-party data processors which means that they are only permitted to process your personal data for specified purposes and in accordance with our instructions and applicable laws.

International transfers

We do not generally process personal data outside the United Kingdom or European Economic Area, but we may do so where necessary for the purposes set out in this privacy notice and certain third-party service providers may transfer and process personal data outside the UK or EEA.  We will only do this, or allow third parties to do so, where we are satisfied that your data is protected by equivalent laws and/or appropriate safeguards.  To obtain further information, please contact us using the details above.

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, agents, contractors and 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.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

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. We will take all reasonable steps to destroy, or erase from our systems, all the personal information we hold about you when it is no longer required.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. The rights available to you depend on our reason for processing your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request” or “subject access request”). This enables you to receive a copy of the personal data we hold about you.  You can always rely on this right, but there are some exemptions, which means you might not always receive all the information we process.
• 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 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 certain circumstances.
• Request the transfer of your personal data to you or to a third party. This only applies to information you have given us.

If you wish to exercise any of the rights set out above, please contact us at dpo@zigup.com or via the postal address above.

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 could refuse to comply with your request in these circumstances.

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Complaints

You have the right to make a data protection complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at dpo@zigup.com or via the postal address above.

If you remain dissatisfied, or you would prefer not to discuss the issue with us, you can make a complaint to the ICO using the following contact details: https://ico.org.uk/make-a-complaint/ or Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or telephone: 0303 123 1113.