Privacy Policy


We are  committed to protecting your personal data. This privacy policy will inform
you   as   to   how   we   look   after   your   personal   data   when   you   visit   our   website (“Website”) (regardless of where you visit it from) and tell you
about your privacy rights and how the law protects you.


This privacy policy aims to give you information on how we collect and process your
personal data through your use of this Website, including any data you may provide
through this Website.

This   Website   is   not   intended   for   children   and   we   do   not   knowingly   collect   data
relating to children.

This   privacy   policy   will   inform   you   how   you   can   verify   which   of   your   personal
information is collected by us through the Website and how you can request that we
delete, update or transfer it.

It   is   important   that   you   read   this   privacy   policy   together   with   any   other   privacy
policy or fair processing policy 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 policy supplements other notices and
privacy policies and is not intended to override them.


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 as follows:

• Identity Data  includes   first  name,  last  name,  username   or  similar  identifier,
title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other
details of products and services you have purchased from us.
• 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,   your   interests,
preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website, products and
• Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data could be derived from your personal data but
is not considered personal data in law as this data will not directly or indirectly reveal

your   identity.   For   example,   we   may   aggregate   your   Usage   Data   to   calculate   the
percentage of users accessing a specific website feature. However, if we combine or
connect Aggregated Data with your personal data so that it can directly or indirectly
identify   you,   we   treat   the   combined   data   as   personal   data   which   will   be   used   in
accordance with this privacy policy.

We do not collect any Financial Data (this includes bank account and payment card
details)   or   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.


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 (for example, to
provide you with goods or services). In this case, we may have to cancel a product or
service you have with us but we will notify you if this is the case at the time.


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

• Direct interactions.  You   may   give   us   your   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 our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you; or
• 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.
• Third parties or publicly available sources.  We will receive personal data
about you from various third parties and public sources as set out below:
• Technical Data from analytics providers
• Contact   and   Transaction   Data   from   providers   of   technical,   payment   and delivery services.
• Identity and Contact Data from data brokers or aggregators
• Identity and Contact Data from publicly available sources


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:

• 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 (or those of a third party) and your
interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation. Generally, we do not rely on
consent as a legal basis for processing your personal data although we will get
your consent before sending third party direct marketing communications to you
via email or text message. You have the right to withdraw consent to marketing
at any time by contacting us.


Our Website uses certain cookies, pixels, beacons, log files and other technologies of
which you should be aware. Please see our Cookie Policy to find out more about the
cookies we use and how to manage them.


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


It is likely that the Website will contain links to third party websites and services.
Please   remember   that   when   you   use   a   link   to   go   from   our   Website   to   another
website or  you  request a service from  a third  party,  this privacy policy  no longer
Your browsing and interaction on any other website, or your dealings with any other
third-party   service   provider,   is   subject   to   that   website’s   or   third   party   service
provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website
you visit or third party service provider that you deal with and to contact them if you
have any questions about their respective privacy policies and practices.
This privacy policy applies solely to personal information collected by us through our
Website and functionality and does not apply to these third party websites and third
party service providers.


The  EEA,  UK  and   other  countries  outside  the   EEA   and   the   UK  have  differing  data
protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside
the   UK and   EEA.   In   those   cases   we   will   comply   with   applicable   UK and   EEA   laws
designed to ensure the privacy of your personal data.
As we are based in the UK we will also transfer your personal data from the EEA to
the UK.
Other than as set out above, we do not transfer your personal information outside of
the EEA or UK.
If   you   would   like   further   information   about   data   transferred   outside   the   UK/EEA,
please contact us via


We are committed to keeping the personal information you provide us secure and we
will   take   reasonable   precautions   to   protect   your   personal   information   from   loss,
misuse or alteration.
We have implemented information security policies, rules and technical measures to
protect the personal information that we have under our control from:
ounauthorised access;
oimproper use or disclosure;
ounauthorised modification; and
ounlawful destruction or accidental loss.
All   our   employees   and   data   processors   (i.e.   those   who   process   your   personal
information on our behalf, for the purposes listed above), who have access to, and
are associated with the processing of personal information, are obliged to respect
the confidentiality of the personal information of all users of the Site.


You have the following rights in relation to the personal information we hold about

Your right of access.

If   you   ask   us,   we’ll   confirm   whether   we’re   processing   your   personal
information   and,   if   so,   provide   you   with   a   copy   of   that   personal
information (along with certain other details). If you require additional
copies, we may need to charge a reasonable fee.

Your right to rectification.

If   the   personal   information   we   hold   about   you   is   inaccurate   or
incomplete,   you’re   entitled   to   have   it   rectified.   If   we’ve   shared   your
personal   information   with   others,   we’ll   let   them   know   about   the
rectification where possible. If you ask us, where possible and lawful to do so,
we’ll also tell you who we’ve shared your personal information with so that you
can contact them directly.

Your right to erasure.

You can ask us to delete or remove your personal information in some
circumstances   such   as   where   we   no   longer   need   it   or   you   withdraw
your   consent   (where   applicable).   If   we’ve   shared   your   personal
information with others, we’ll let them know about the erasure where
possible. If you ask us, where possible and lawful to do so, we’ll also
tell you who we’ve shared your personal information with so that you
can contact them directly.

Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal
information   in   certain   circumstances   such   as   where   you   contest   the
accuracy of that personal information or object to us processing it. It
won’t stop us from storing your personal information though. We’ll tell
you   before   we   lift   any   restriction.   If   we’ve   shared   your   personal
information   with   others,   we’ll   let   them   know   about   the   restriction
where possible. If you ask us, where possible and lawful to do so, we’ll
also tell you who we’ve shared your personal information with so that
you can contact them directly.

Your right to data portability.

With   effect   from   25   May   2018,   you   have   the   right,   in   certain
circumstances, to obtain personal information you’ve provided us with
(in a structured, commonly used and machine readable format) and to
reuse it elsewhere or ask us  to transfer this  to a third party of your

Your right to object.

You can ask us to stop processing your personal information, and we
will do so, if we’re:

- relying   on   our   own   or   someone   else’s   legitimate   interests   to
process your personal information except if we can demonstrate
compelling legal grounds for the processing;
- processing your personal information for direct marketing; or
- processing   your   personal   information   for   research   unless   such
processing   is   necessary   for   the   performance   of   a   task   carried
out in the public interest.

Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on
automatic processing, including profiling, and it produces a legal effect
or similarly significantly affects you unless such profiling is necessary
for entering into, or the performance of, a contract between you and

Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for
processing your personal information, you have the right to withdraw
that consent at any time.

Your right to lodge a complaint with the supervisory authority.

If   you   have   a   concern   about   any   aspect   of   our   privacy   practices,
including   the  way we’ve  handled  your  personal  information, you  can
report it  to  the  UK   Information  Commissioner’s  Office  (ICO). You  can
find   details   about   how   to   do   this   on   the   ICO   website
at or by calling their helpline on 0303 123


We may make changes to this privacy policy from time to time.
To ensure that you are always aware of how we use your personal information we
will update this privacy policy from time to time to reflect any changes to our use of
your personal information. We may also make changes as required to comply with
changes in applicable law or regulatory requirements. We may notify you by e-mail
of any significant changes. However, we encourage you to review this privacy policy
periodically to be informed of how we use your personal information.


If you have any questions about this privacy policy or want to exercise your rights,
please contact us by:
Sending an e-mail to; or to address 15 Bishopsgate, London EC2N 3AR

Last update: November 2022