Anglia Registrars Limited (trading as Inform Direct) (“we”, “us”, “our”) are committed to protecting and respecting your privacy.
This policy (together with our Terms of Website Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.
Who we are and how you can contact us
We are Anglia Registrars Limited, a private limited company, with company number 07887285 and whose registered office is located at Clydesdale House, 1-5 Queen Street, Ipswich, Suffolk IP1 15W.
You can contact us in writing at Clydesdale House, 1-5 Queen Street, Ipswich, Suffolk IP1 15W or by emailing [email protected].
Information we collect from you
We will collect and process the following personal data about you:
Personal data you give us
This is information about you that you give us by filling in forms on our website informdirect.co.uk (“our site”) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, submit to anti-money laundering checks, subscribe to our service, place an order on our site, participate in discussion boards or manage your company through our site, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, occupation and gender.
Personal data we collect about you
With regard to each of your visits to our site we will automatically collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, linked websites visited from our sites, and information about your visit, including page interaction information.
Personal data we receive from other sources
This is information we receive about you if you use any of the other websites we operate or the other services we provide. In such cases, these third parties may collect personal data about you which they will share with us. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, identification verification and fraud prevention agencies).
Uses made of your personal data
We use personal data held about you in the following ways:
Personal data you give to us
We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with marketing information in accordance with your marketing preferences (see Your rights – how we use your personal data for marketing);
- to notify you about changes to our service;
- to review and improve our service;
- to manage and administer our business;
- to ensure that content from our site is presented in the most effective manner for you and for your computer;
- to meet our legal obligations.
Personal data we collect about you
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Personal data we receive from other sources
We will combine this information with any personal data you give to us and personal data we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
When we need your consent to use your personal data
Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:
- we are entering into and carrying out our obligations under a contract with you;
- we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights; or
- we are required to process your personal data to meet out legal obligations, for example, obtaining proof of identity to enable us to meet out anti-money laundering obligations.
In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.
Please refer to the section entitled Your rights – how we use your personal data for marketing to read about marketing consents.
Personal data you are legally obliged to provide
You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our services to you.
Disclosure of your personal data
We share your data with the following people in the day to day running our business:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, including, but not limited to, providers of registered office services;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
- identity verification and fraud prevention providers, where it is a condition of us entering into a contact with you to run anti-money laundering checks.
We may also disclose your personal data to third parties on a one-off basis, for example, if:
- we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- Anglia Registrars Limited or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
Where we store your personal data
We take every care to ensure that your personal data is kept secure. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights – how we use your personal data for marketing
We will add your details to our marketing database if:
- you make an enquiry about our services;
- you buy our services;
- you have told a third party that you would like them to pass us your contact details so that we can send you updates about our services;
- you have registered an account on our website and have indicated during the sign up process that you are happy to receive marketing communications.
We may send you marketing communications by email, telephone, automated calls, text message, post.
You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), about specific subjects) or you may ask us not to send you any marketing communications at all.
We may ask you to indicate your marketing preferences when you first register an account on our site. You can check and update your current marketing preferences at any time by logging into your account on our site or emailing us using the details set out in the Contact Us section below.
We will only share your personal data with third parties for marketing purposes if you provide us with your consent to do so by ticking a box on a form we use to collect your personal data.
You have the right to ask us not to process your personal data for marketing purposes at any time. If you wish to do so, please contact us at Clydesdale House, 1 – 5 Queen Street, Ipswich, Suffolk IP1 1SW or email [email protected].
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Third party sites and services
As mentioned above, our site contains links to other third party sites, products and services. If you choose to visit these sites and/or purchase their products or services, we encourage you to review the privacy policies of those third parties to determine how they will collect, use and share your information. We are not responsible for the privacy statements or other content on third party websites, nor can we be held liable for the way in which those sites choose to handle your personal information.
Access to information
You have a legal right to know what personal data we hold about you – this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to us Clydesdale House, 1-5 Queen Street, Ipswich, Suffolk IP1 15W or by emailing [email protected].
You also have rights to:
- prevent your personal data being used for marketing purposes (see Your rights – how we use your personal data for marketing for further details);
- have inaccurate personal data corrected, blocked or erased;
- object to our using your personal data in ways that are likely to cause you damage or distress;
- restrict our use of your personal data;
- require that we delete your personal data;
- require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file.
You can find full details of your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.
Automated decision making and profiling
Save as described in this section, we do not make use of automated decision making or profiling.
- Where we are required under anti-money laundering regulations to carry out identity checks (this will principally occur where private customers are seeking to incorporate companies using our services), we will pass your personal data to our third party contractor Onfido Ltd, or such other provider as shall replace it for this purpose (“our provider”). Our provider may also collect personal data from you directly.
- Anti-money laundering checks carried out by our provider will often constitute automated decision making which produces legal effects or which similarly significantly affects an individual, and as such will be subject to the restrictions contained in data protection legislation.
- Under data protection legislation, we and our provider are permitted (subject to the rest of this section) to carry out such automated decision making because it is being done for a reason required by law (anti-money laundering checks) and is a reasonable, appropriate and proportionate way to achieve this requirement.
- We will notify you in writing where a decision has been taken based solely on automated processing as soon as practicable after the decision has been taken.
- You may, within the period of one month beginning with receipt of this notification, request us to provide the decision or take a new decision that is not based on automated processing.
- If you make such a request, we must consider and comply with the request without undue delay and within one month (or two in the case of complex matters).
How long we keep your personal data
We only keep your personal data for as long as we actually need it. In practice this means that we will keep:
- your name, contact details and a record of the services we provided to you, including invoices, for up to 6 years after closing your account, or making a purchase from the website where an account is not required;
- complaint records for up to 5 years;
- the details and documents provided for anti-money laundering checks (where provided) for up to 5 years after closing your account;
- data submissions and collections made to and from Companies House for up to 45 days;
- email, live chat and ‘contact us’ correspondence for up to 3 years;
- billing information, including card details, are kept by our payment provider for up to 7 years from last use;
- your contact details, where provided to subscribe to receive news on our website for 20 years;
- your name and contact details when commenting on the website for 30 years.
Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.
How you can make a complaint
If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out below.
You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.
How we keep this policy up to date
We will review and update this policy from time to time. This may be to reflect a change in the services we offer or to our internal procedures or it may be to reflect a change in the law.
The easiest way to check for updates is by looking for the latest version of this policy on our website (www.informdirect.co.uk) or you can contact us (see Contact Us) to ask us to send you the latest version of our policy.
Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.
This is policy version 3 which came into effect on 12th November 2018.