Money Advice Scotland ("we", "us" or "our") respects your privacy and is committed to protecting your personal data. We are the controller of personal data processed in connection with this Policy and are registered with the ICO as a data controller under registration number Z8026262.
In this Policy, “Data Protection Legislation” means all applicable legislation which relates to the protection of individuals with regards processing personal data, including the General Data Protection Regulation (EU) 2016/679.
2. INFORMATION THAT WE COLLECT FROM YOU
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, maiden name, last name, username or similar identifier; marital status, title, date of birth and gender;
- Contact Data: includes postal address, email address and telephone numbers;
- Financial Data: includes whether you are, or have previously been, declared bankrupt and your Trustee has instructed that you undergo financial education training with Money Advice Scotland;
- 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, survey responses and information about which training you have undertaken, or attendance at conference or consultation events;
- Usage Data: includes information about how you use our website, products and services and your attendance at events and
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preference.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We collect information you provide to us when you:
- contact us through our helpline and our webchat service;
- sign up to and complete a Castlight Affordability Passport
- sign up to and complete our online financial education e-modules;
- sign up to receive our newsletters;
- request information on any of the services that we offer;
- fill in any forms on our website; and
- create an account on our website.
We do not collect personal information about you from third parties.
4 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:
- 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; and
- Where we need to comply with a legal or regulatory obligation.
Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.
We use your information:
- to supply you with services and information you have requested;
- to analyse the information we collect so that we can administer, support and improve and develop our business, and our charitable activities, and the services we offer;
- to contact you in order to send you details of our services which may be of interest to you;
- to provide you with access to certain parts of our site;
- for all other purposes consistent with the proper performance of our operations and business;
- to contact you for your views on our products and services; and
- to help us with understanding more about how our website and services are used.
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will explain the legal basis which allows us to do so.
5. DISCLOSURE OF YOUR INFORMATION
The information you provide to us will be treated as confidential. However, we may disclose your information to other third parties who act for us for the purposes set out in the policy or for purposes approved by you, including to suppliers who provide financial services. 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.
We do not share your personal data outside of the EEA.
6. DATA RETENTION
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, including to funders.
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 we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
7. YOUR RIGHTS
Under Data Protection Legislation, you have the right in certain circumstances:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check we are lawfully processing it;
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below);
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes;• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
- Request the transfer of your personal information to another party; and
- Withdraw your consent to the processing of your personal information where we rely on consent to process your personal data.
If you would like to exercise any of your rights above, please contact us using the details below.
You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.
We may amend this policy from time to time. If we make any substantial changes we will notify you by posting a prominent notice on our website or by email.
9. CONTACT US
We have appointed data protection manager (DMO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the [DMO] using the details set out below.
Yvonne MacDermid, Chief Executive, Money Advice Scotland, Suite 410, 36 Washington Street, Glasgow, G3 8AZ. Telephone 0141 572 0238 or email firstname.lastname@example.org
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