The legal stuff
Privacy policy
- 1. Purpose of this Policy
- 2. Who are we and what do we do?
- 3. How to contact us?
- 4. Fraud prevention
- 5. What personal information do we collect and how do we use it?
- 6. How is your personal data collected?
- 7. Our use of cookies and similar technologies
- 8. Storage and Sharing of Personal Information and International Data Exports
- 9. Data Security
- 10. Third-Party Links and Services
- 11. How long do we keep your personal information for?
- 12. Confidentiality and security of your personal information
- 13. How to access your information and your other rights?
- 14. Changes to this Privacy Policy
ANNA respects your privacy and is 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 (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
- This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or that we have obtained about you from a third party and the purposes for which we process your personal information or share it. This Privacy Policy also sets out your rights in respect of our processing of your personal information.
- This website is not intended for children, and we do not knowingly collect data relating to children.
- It is important that you read this Privacy Policy together with any other relevant 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.
- The Sites and our Services are operated by Absolutely No Nonsense Admin Ltd, (“ANNA”, “we”, “us” or “our”) which is the data controller.
- If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact complaints@anna.money.
- If you have any questions about this Privacy Policy or our privacy practices or want to exercise your rights set out in this Privacy Policy, please contact us by:
- sending an e-mail to support@anna.money; or
- write to us at: PO Box 1130, Cardiff CF11 1WF.
- You have the right to make a 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.
- Changes to the Privacy Policy and Your Duty to Inform Us of Changes
- We keep our Privacy Policy under regular review. This version was last updated on 1 March 2024.
- The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- We may collect, use, store and transfer different kinds of personal data about you. Our primary goal in collecting personal information from you is to:
- verify your identity;
- help us improve our services and develop new and services;
- carry out requests made by you on the Sites;
- investigate or settle inquiries or disputes;
- comply with applicable laws, court orders, other judicial processes and the requirements of regulators;
- enforce our agreements with you;
- protect the rights, property and safety of us and third parties, including our other customers and users of the Site;
- provide support for the provision of our Services; and
- use as otherwise required or permitted by law.
- We use your personal information for the following purposes:
- Identity Data includes first name, last name, title, and date of birth
- Contact Data includes home address, business address, email address and telephone numbers
- Financial Data includes bank account and payment card details
- 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 business name and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
- Usage Data includes information about how you use our website, products and services
- 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 per this privacy policy.
- We do not actively collect any Special Categories of Personal Data about you (as defined in UK GDPR and further detailed in the linked ICO guidance). 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. However, there may be circumstances where you provide Special Categories of Personal Data to us during support scenarios (including any investigations relating to scamming).
- Any other purposes for which we wish to use your personal information that is not listed above or any other changes we propose to make to the existing purposes will be notified to you using your contact details.
- 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.
- 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.
- 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.
- Where you provide Special Categories of Personal Data to us during support scenarios, we will also record and use this data for the purposes set out in this privacy policy but only where you have provided us with your explicit consent.
- Purposes for Which We Will Use Your Personal Data
- We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
- Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer | Performance of a contract with you | |
To process and deliver your order including: | ||
To manage our relationship with you which will include: | ||
To enable you to partake in a prize draw, competition or complete a survey | ||
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | ||
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) | |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) | |
To make suggestions and recommendations to you about goods or services that may be of interest to you | Necessary for our legitimate interests (to develop our products/services and grow our business) |
- Necessary for our legitimate interests (to develop our products/services and grow our business)
- Marketing
- We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
- Promotional Offers From Us
- We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing)
- You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing
- Third-Party Marketing
- We will get your express opt-in consent before we share your personal data with any third party for marketing purposes
- Opting Out
- You can ask us or third parties to stop sending you marketing messages at any time
- Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of
- Change Of Purpose
- 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us
- If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so
- 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
- We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial 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
- enter a competition, promotion or survey 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://anna.money/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 the following parties:
- Analytics providers such as Google based outside the UK; advertising networks; and search information providers
- Contact, Financial 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 store some personal data in data centres in the United Kingdom.
- To provide you with some of the services via the Sites, we may need to share your personal data with third-party service providers. We may share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties.
- External Third Parties.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
- We require all third parties to respect the security of your personal data and to treat it following the law. 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 under our instructions.
- We share your personal data within the ANNA Group. This will involve transferring your data outside the UK and EEA.
- We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules"
- Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
- Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
- Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
- 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.
- We keep your personal information for 6 years from the date of our last interaction with you or such longer period as is required by law or regulation.
- If your information is only useful for a short period e.g. for specific marketing campaigns, we may delete it shortly afterwards.
- Please refer to our Cookie Policy for details of how long we retain Cookie data.
- You have the following rights with the personal information we hold about you:
- Your right of access. You have the right to request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Your right to correction. You have the right to 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.
- Your right to erasure. You have the right to request the 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.
- Your right to restrict processing. You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy
- Where our use of the data is unlawful but you do not want us to erase it
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
- Your right to data transfer. You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Your right to object. You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) 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.
- Your right to withdraw consent. You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- We may make changes to this Privacy Policy from time to time and we will update you if we make any changes to this Privacy Policy.
Absolutely No Nonsense Admin Ltd
Brunel House
2 Fitzalan Road
Cardiff
Wales
CF24 0EB