Privacy Policy

Privacy Policy & Fair Processing Notice

Please read this Privacy Policy & Fair Processing Notice carefully. By using any of the services that are set out in our Terms & Conditions you agree to be bound by this Privacy Policy.

You must not use this website or our Services if you do not accept this Privacy Policy.

 

If you are providing us with another person’s information you should first, ask them to read this Privacy Policy and our Terms & Conditions.

By giving us information about another person you are confirming that they have given you consent to provide the information to us and that they understand how their details will be used.

1) Who are we?

Fifty Seven Digital Limited includes the brand Code Galaxy (www.codegalaxy.co.uk). Fifty Seven Digital Limited is committed to protecting and respecting your privacy and will comply with the applicable data protection laws in all our dealings with your personal data.

This Privacy Policy & Fair Processing Notice explains how we will use information about you and the steps we take to ensure your information is kept secure and confidential. It should be read together with our Terms & Conditions.

2) How do we collect information?

We may obtain information from you through the websites, mobile applications Telephone Interviews or other similar devices, channels or applications operated by or on behalf of any of the following brands (referred to collectively in this Privacy Policy as the “Sites”):

• Fifty Seven Digital Limited
• Code Galaxy ( co.uk )

Fifty Seven Digital Limited (company number 10964537) is the data controller in relation to the processing of the personal information that you provide to us when using the Services. Its registered address is Galaxy House Aldon Road, Poulton Industrial Estate, Poulton-Le-Fylde, Lancashire, England, FY6 8JL. If you have any queries relating to our use of your personal information, or any other related data protection questions, please contact our Customer Services Team at greetings@codegalaxy.co.uk.

3) Legal Basis to Process Your Personal Data

Under the applicable data protection laws, we need a lawful basis to collect and use your personal data. The law allows for six lawful bases to process people’s personal data, and one of them allows personal data to be legally collected and used if it is necessary for a legitimate interest of the organisation – as long as it is fair and balanced and does not unduly impact the rights of individuals.

Due to the nature of our business and the size of our databases, it is not practical for us to ask every individual for his/her consent. We have assessed our and our clients’ business interests in carrying out marketing activities and we have carefully considered the impact the collection and use of personal data could potentially have on individuals’ rights. Our databases contain business data, which is used to promote business in the UK and such activities are unlikely to affect the fundamental rights and freedoms of individuals concerned. We have therefore concluded that the most appropriate lawful ground for the processing of your personal is our and our client’s legitimate interests.

In the event you request any goods and/or services from us, we will rely on our contractual relationship to process your personal data to provide such goods and/or services to you.

In certain very limited circumstances we may also rely on a specific consent provided by you for the processing of your personal data. In those circumstances you can withdraw your consent at any time by contacting us – see our contact details below.

4) What information do we collect?

We collect personal information about you when you give this to us in the course of registering for and/or using our Services via any of the Sites, or through the telephone interviews conducted on our behalf or on the behalf of our fleet specific partners. This might be, for example, to obtain clarity of your requirements for fleet specific services. In the course of providing the Services to you, we may also store information about how you use our Sites, for example, the pages viewed, the website from which you came to visit our sites, changes you make to information you supply to us, details of the quotes you request and your feedback.

To provide you with a quote we may need to collect personal information which data protection legislation defines as sensitive. By proceeding with obtaining a quote you give your explicit consent to such information being processed by us and our third-party providers for the purposes stated in this Privacy Policy. We will store the information you provide and may use it to pre-populate fields on the sites to make it easier for you to use when making return visits. If you do not want us to store and use your information in this way, you may amend your preferences by emailing us at greetings@codegalaxy.co.uk (see also section 11 How can you amend your preferences? below).

We may monitor or record your calls, emails, SMS or other communications but we will do so in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training (e.g. where you call our customer services help line), to prevent unauthorised use of our telecommunication systems and sites, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime.

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law.

5) How do we use your information?

We may use your personal information:

1. to enable you to access and use the Services;
2. to personalise and improve aspects of our Services;
3. for research, such as analysing market trends and customer demographics;
4. to communicate with you, including some or all of the following:

sending you information about products and services which we think may be of interest to you– this may include new product launches, newsletters and opportunities to participate in market research;

sending you annual renewal suggestions based on information you previously provided to us (if you have requested quotes) – when our systems indicate that your renewal is due (based on the dates you entered for your most recent quote) we may resubmit your quote details to give you an idea of what your quotes could be for your next renewal.

sending you a confirmation email of your quote– when you obtain a quote with us, you may automatically be sent confirmation of your quote by email or SMS so that you have a record of it and can easily retrieve your quote in the future. This may be a standard part of our Services and by using the Services you agree to receive these communications;

To notify you about changes to our service – We are continually updating our services, to improve the efficiency of how we can support companies to find the best fleet specific supplier for their needs, we may contact you to inform you of the changes made

1. to process a transaction between you and a third party;
2. to search the websites of our partners in order to obtain the best quotes available to you;
3. to track sales, which may involve us sharing data with your product provider relating to the product(s) you have purchased. Your product provider may also send us information they hold relating to the product(s) you have purchased for this purpose;
4. to match our data with data from other sources – we may validate and analyse your information and, in some cases, match it against information that has been collected by a third party to ensure that the information we hold about you is as accurate, consistent and well-organised as possible. As well as ensuring that any marketing material that we send you is appropriate to your needs, this process also ensures that our Services continue to be as personalised and focused as possible;
5. to populate our customer insight products which are available to subscribers;
6. to enable you to share our content with others, e.g. by using any ‘Email a friend’ or ‘Share this’ functionality on our Sites.
7. Promote our client’s goods and services which include direct marketing;
8. Provide our clients with databases to enable our clients to promote their goods and services for content specific to the use and management of company vehicles;
9. Trace individuals, verification and/or validation of the identity of individuals for the purposes, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification;
10. We may share information, including personal data, with the following categories of third parties (which will allow your business to be found via online search engines or online directories, and also by prospective suppliers), These third parties will always be company related suppliers of business to business goods and services or their respective agencies, such as:

• Employment and recruitment agencies.
• Credit reference agencies.
• Marketing list providers.

Requesting to be kept informed about our services: You agree that we and other trusted third parties will be entitled to contact you (depending on your contact preferences) via email, post, telephone, SMS, or by other electronic means such as via social and digital media, in relation to products, services and other offers that may interest you and your business.

Whenever you provide us with personal information, where necessary we will seek your consent, and/or we will give you an opportunity to tell us you do not consent to the use and sharing of your information for marketing purposes. Unless you tell us otherwise, you are consenting to such use.

6) Who do we share your information with?

When you use any of our Services, you consent to us disclosing your personal information to the following parties:

1. our partners including but not limited to companies whose products or services are included on our Sites, with a view to them: (i) providing you with an online quote for the product/service requested by you. When these companies use your information in this way, they will be acting as data controllers of your information and therefore we advise you to read your chosen provider’s Privacy Policy; and/or (ii) using our customer insight products to understand customer behaviours and develop their product offerings. Some third parties with whom we share your information may use it to carry out research such as analysis of market trends and customer demographics and to customise and develop the product/service which they offer to you or other individuals in the future;
2. our channel operators: whilst many of the channels on our Sites are run by us, some of our channels are designed and maintained for us by our third-party service providers. We may receive your personal information from these service providers and use it in accordance with section 4 above. We will only use the personal information we receive from third parties where the relevant third party can show that it was collected and processed with your consent;
3. trusted third parties but only where we believe their products, services or other offers may interest you, and there be a legitimate interest in company vehicle related services.

Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account:

1. if required or permitted to do so by law;
2. if required to do so by any court, the Financial Conduct Authority, the Competition and Markets Authority or any other applicable regulatory, compliance, Governmental or law enforcement agency;
3. if necessary, in connection with legal proceedings or potential legal proceedings; and/or
4. in connection with the sale or potential sale of all or part of our business.

If we reasonably believe false or inaccurate information has been provided and fraud is suspected, details may be passed to fraud prevention agencies to prevent fraud and money laundering.

7) Who might our providers share your information with?

Some of our providers will use your personal information to assess your circumstances (including information about any third party who is named on the policy) and verify the information that you have provided before providing a quote to you. Some providers may carry out checks with fraud prevention and credit reference agencies. Both public data (e.g. the electoral roll) and private data (e.g. your personal credit history) may be checked in this way. Some providers may carry out checks against data they already hold on you, (or is held by the company whose brand they administer the product for, or members of their group of companies) such as data from existing products, account data, data from previous product transactions, accounts you may hold with them or loyalty scheme data to share with insurers in order to determine your premium. Providers may also exchange data with certain industry databases such as the No Claims Discount Database, the Motor Insurance Anti-Fraud and Theft Register, the Claims and Underwriting Exchange (which holds records of incidents reported to insurers that may or may not have resulted in a claim) and the Hunter Database (a central insurance and claims checking system). If providers carry out these searches, a record of the search will appear on your credit report. Some providers may also check public and private higher education sources to obtain information about your educational background.

This information exchange allows providers to verify the information that is provided during the quote process (including information about any third party who is named on the policy) and helps to detect fraudulent claims. Providers may also share information with insurance underwriters. These checks are not unique to users of our Services – they may also be carried out if you obtain quotes from other sources.

If you decide to enter into a contract with a third-party provider through any of the Sites, the information you have provided to us, together with any further information requested by, and supplied by you or us to the third-party provider, will be held by the provider for the purposes set out in that provider’s privacy policy. Therefore, you are strongly advised to read your chosen provider’s privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the contract. We have no responsibility for the uses to which a provider puts your personal information.

8) What cookies do we use?

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.

We may at one time or another use three types of cookies on our website

• Session cookies that are deleted after each visit
• Persistent cookies that remain in place across multiple visits to our sites
• Third party cookies that are used by our approved business partners.

Google Analytics – This cookie enables us to access all web traffic. This means we can improve your browsing experience by making informed decisions from the user data collected.

Google conversion code – Our website may use conversion code tracking to establish whether an advertisement has driven an enquiry.

Remarketing – We may use remarketing advertising to deliver targeted advertising messages to users that have previously shown in interest in our website. We apply strict rules to our remarketing campaigns, so you will only receive targeted messages and do not receive multiple advertisements.

Data capture – The enquiry forms within our website capture a user’s data prior to form submission. This is so we can further improve the user journey and perform a customer service call (if needed) to ensure the user had obtained all of the information required from our website.

For further information visit www.aboutcookies.org or www.allaboutcookies.org

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

9) What advertisements do we show on our Sites?

The advertisements that you see displayed on our Sites are delivered on our behalf by certain third-party advertising companies. No information which identifies you, for example your name, address, email address or telephone number, is used to provide this advertising. In order to display advertising most likely to be relevant to you, these third-party advertisers may place or recognize a unique cookie on your browser. This cookie does not collect personal information about you nor is it linked to any identifiable information about you. It is possible to block cookies by adjusting your browser settings, as mentioned above. By using the Services, you are consenting to the use of these third-party cookies for these purposes.

If you would like more information about online advertisements and your choices about how this information may be used by these companies, please click here http://www.youronlinechoices.com/uk/your-ad-choices.

1. How secure is our site and what steps do we take to keep you safe?

Our Sites are secured using an SSL certificate and keeping information about you secure is very important to us. However, no data transmission over the internet can be guaranteed to be totally secure. Sensitive information, for example, your credit card details, is encrypted to minimise the risk of interception during transit.

You may complete a registration process when you sign up to use parts of the Sites. This may include the creation of a username, password and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone. Where you do disclose any of these details, you are solely responsible for all activities undertaken on the Sites where they are used. To protect your account, we ask you to choose a strong password to access your information on our Sites. A strong password should include a mixture of letters and numbers. Your password can only be reset with access to the email address registered in our system.

We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us, and you do so at your own risk. By using our Sites, you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

1. How can you amend your preferences?

Any electronic marketing communications we send you will include clear and concise instructions to follow should you wish to unsubscribe at any time. You may also amend your marketing preferences by emailing us at greetings@codegalaxy.co.uk.

Should you no longer wish to be contacted by us, you can advise us at any time by contacting our Customer Services team by sending an email to greetings@codegalaxy.co.uk

You may also ask us at any time to stop passing your information to third parties for marketing purposes. Such a request may result in us ceasing to offer the Services to you.

If you no longer wish to be contacted by third parties for marketing purposes, please follow the instructions in their marketing communications, or consult their privacy policies for further information about unsubscribing.

1. Your rights and responsibilities

You have certain rights under data protection legislation. For example, we will always let you have a copy of the personal information we hold about you free of charge, if you request it from us in writing.

We do reserve the right to request a reasonable fee to cover administrative costs should a request be manifestly unfounded or excessive, particularly if it is repetitive.

You have the right to:

• Request to see the personal data we hold about you. This includes the right to obtain a confirmation as to whether or not we process any of your personal data;
• Request that we correct any inaccuracies in the personal data that we hold on you;
• From May 2018, in certain circumstances you may have the right to be forgotten (i.e. to have your personally identifiable data deleted). In many cases we would recommend that we supress you from future communications, rather than data deletion;
• In certain situations, you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage;
• Request that we do not process your personal data for direct marketing and that we will keep your contact details to ensure that no further contact is made;
• Object to our processing of your personal data if we are relying on legitimate interest as the lawful ground for processing; and
• Request the transfer of any personal data you have provided to us to a different organisation.

To make enquiries and/or exercise any of your rights set out in this Privacy Policy please contact our Customer Services Team at greetings@codegalaxy.co.uk.

We may also ask you for proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill). This is so that we can check that any information we disclose is only provided to the authorised party.

If you have any concerns or complaints about our privacy activities, you can contact us on greetings@codegalaxy.co.uk . You can also contact the Information Commissioner’s Office on 0303 123 1113 (www.ico.org.uk).

To ensure the Services, we provide you continue to meet your needs we may ask you for feedback on your experience of using the Sites. Any feedback you provide will only be used as part of our programme of continuous improvement and will not be published on the Sites.

Note that it is your responsibility to check and ensure that all information, content, material or data you provide on the Sites is correct, complete, accurate and not misleading and that you disclose all relevant facts.

This Privacy Policy and Fair Processing Notice shall be governed and construed in all respects in accordance with the laws of England and Wales.

We reserve the right to amend or modify this Privacy Policy at any time and any changes will be published on the Sites.