Privacy Policy

1. Introduction

You have certain rights in relation to your data, including the right to object to processing on legitimate interests, profiling (including the use of customer and lookalike/similar audiences), and direct marketing. At any time, you can exercise your rights by emailing us at yourdata@polly.co.uk.

For further details about our processing and your rights, please see below.

2. About our site

Our site enables people to request quotes or information for the product or service shown or selected on the site. The service that our site provides is to further your request for the product or service in question by introducing you to an appropriate financial adviser, intermediary or provider.

3. How our site works

If you would like to request and receive quotes or information for a product, please complete and submit our web form. Once we have received your request, we’ll connect you with one or more relevant financial advisers, intermediaries or providers. We’ll tell the financial adviser, intermediary or provider, who you are, and your product requirements and they’ll then contact you directly with your requested quotes.

You are under no obligation to purchase any product or service and you will not be charged for the initial consultation.

We only work with financial advisers, intermediaries and providers who we have a legal contract in place with. This is to ensure that they respect your data and rights by keeping your data secure and confidential, limiting their use of your data and not sharing your data with anyone else.

4. About us

Polly.co.uk is a brand of Candid Web Assets Ltd, a company registered in England and Wales, company number: 07279489 whose registered office is 85 Whiteladies Rd, Bristol BS8 2NT.

For the purposes of the General Data Protection Regulation (GDPR), Candid Web Assets Ltd is the controller in relation to your data. We are registered as a controller with the UK Information Commissioner’s Office (ICO) under registration number: Z3488836.

Candid Web Assets Ltd is authorised and regulated by the Financial Conduct Authority, registration number: 603273.

5. What data we collect and how

If you choose to complete our web form in order to request quotes or information you will be asked for details in regards to who you are, how old you are, how we can contact you along with product specific questions to allow us to fulfil the service request.

We will also store Internet Protocol (IP) addresses and date / time stamps in relation to your request.

6. How we use your data

We use your data in the following ways:

a) If you submit one of our web forms we will pass your request to one or more relevant financial advisers, intermediaries or product providers. We will do this in a secure way, for example using secure HTTPS connections. The financial advisers, intermediaries or product providers will then contact you directly with your quotes. They may contact you by telephone, text/SMS or email.

Before we pass your request to any financial advisers, intermediaries or product providers, our computer systems may use an element of automated decision making. Our computer systems may automatically assess your product requirements and pass your request to such financial advisers, intermediaries or product providers that would like to receive requests for quotes at the time your request is made or who we feel are best suited to fulfil your request.

b) For certain products or situations we may call you to confirm your details or requirements and before we connect you with a financial adviser, intermediary or product provider.

We may also call you to ask about your experience using our site and service and dealing with the financial adviser, intermediary or product provider with which we connected you.

c) To email you about similar products and services. You will always be given an opportunity to opt-out of such messages before we send them, and we will not send such messages if you have opted out.

d) To create custom and lookalike/similar audiences.

We work with Facebook, Google and other advertising platforms to reach our customers. When doing this your data, along with other data, may be used to create a custom audience. This process helps us identify other like minded people who may also be interested in our services, which helps make our advertising more relevant to the people seeing it.

e) We work with a number of suppliers, who process data on our behalf. These include cloud storage providers, email service providers, web hosting companies and technology companies who provide data validation services.

We have appropriate contracts in place with such suppliers to ensure the protection and confidentiality of data.

7. Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. At the bottom of this policy, we have included a table, setting out what cookies we use, and the purpose for which we use them.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.aboutcookies.org or http://www.allaboutcookies.org .

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout .

8. Transferring your data

We do not transfer your data outside of the European Economic Area (EAA).

9. Storing your data

We have a data retention policy, which clearly sets out how long we keep data for, and for what reasons.

We will keep your data only for as long as is necessary to fulfil the purpose/s for which it was collected in the first place, i.e. as set out in this notice.

For example:

- We will keep your request for quotes for 7 years after you make the request to enable us to resolve any queries from a financial adviser, intermediary or product provider, should they arise, and to satisfy regulatory requirements

- If you haven’t opted out of receiving marketing from us, we will keep your details, and send you emails, until such time as you don’t engage with our emails for a period of 12 consecutive months

10. Legal basis for processing and storing your data

This notice sets out how we use your data. Under the GDPR, controllers must have a valid lawful basis for each processing activity that they undertake. This section sets out our lawful basis for each activity.

Activity

Lawful basis under GDPR

Your Rights

To connect you with relevant Service Providers

Consent

To withdraw your consent, as explained below

The automated decision-making explained above

Legitimate Interest

You have the right to object to processing based on legitimate interests

Using and sharing IP addresses

Legitimate Interest

You have the right to object to processing based on legitimate interests

To call you to confirm your details or requirements

Consent

To withdraw your consent, as explained below

Sharing call recordings with Service Providers

Legitimate Interest

To object to processing based on legitimate interests

To email you about similar products and services

Legitimate Interest

To object to processing based on legitimate interests. You also have the right to object to direct marketing

To create custom and lookalike/similar audiences

Legitimate Interest

You have the right to object to processing based on legitimate interests

Receiving data from Service Providers

Legitimate Interest

You have the right to object to processing based on legitimate interests

11. Your Rights

Under the GDPR, you have a number of rights. In relation to our site, and the service that we provide, those rights are set out in the table above. We further explain these rights, and your other rights, below.

- Right of access – You have the right at any time to ask us for a copy of the personal information that we hold about you, and to check that we are lawfully processing it.

- Right of rectification – If personal information that we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.

- Right of erasure – In certain circumstances, you have the right to request that personal information we hold about you is erased (e.g. if the information is no longer necessary for the purposes for which it was collected or processed).

- Right to object to or restrict processing – In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests, and there are no compelling legitimate grounds for our processing which override your rights and interests.

- Right of data portability – In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.

- Right to withdraw consent – In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

12. Contacting Us

If you have any questions regarding this notice, or any questions relating to data protection or privacy, you can contact us at yourdata@polly.co.uk or writing to:

The Data Protection Officer

C/o Candid Web Assets Ltd

85 Whiteladies Rd

Bristol

BS8 2NT

Cookies we use

Cookie

Purpose

Universal Analytics (Google)

These cookies collect information about how visitors use our website. We use the information to compile reports and to make improvements. The cookies collect information in an anonymous form, including where visitors have come to the website from and the pages they visited. To opt-out: https://tools.google.com/dlpage/gaoptout

Taboola Retargeting

These cookies are used to tailor Taboola adverts to a user’s previous viewing habits. For instance, if you have previously visited our page, you may then see other adverts related to that product or service. Taboola is an ad network that shows sponsored content, usually as links below the article on major news sites.

Outbrain Retargeting

These cookies are used to tailor Outbrain adverts to a user’s previous viewing habits. For instance, if you have previously visited our page, you may then see other adverts related to that product or service. Outbrain is an ad network that shows sponsored content, usually as links below the article on major news sites.

Adwords Retargeting (Google

These cookies are used to adjust the targeting of our paid search and display advertising to show ads to users who have previously been to our sites and/or engaged with our page such as completing a form. They contain no personal information.

DoubleClick Retargeting

These cookies are used to adjust the targeting of our display advertising to show ads to users who have previously been to our sites and/or engaged with our page such as completing a form. They contain no personal information.

Taboola Conversion Tracking

These cookies measure ad conversions and optimise spend for advertising campaigns served on Taboola.

Outbrain Conversion Tracking

These cookies measure ad conversions and optimise spend for advertising campaigns served on Outbrain.

Adwords Conversion Tracking

These cookies measure when a user has completed an action on site such as completing a form. They contain no personal information.

Bing Conversion Tracking

These cookies measure when a user has completed an action on site such as completing a form. They contain no personal information.

DoubleClick Conversion Tracking

These cookies measure when a user has completed an action on site such as completing a form. They contain no personal information.

Facebook Pixel

These cookies measure ad conversions, optimise and build audiences for advertising campaigns served on Facebook. To opt-out: https://www.facebook.com/policies/cookies/ .

Twitter Pixel

These cookies measure ad conversions and optimise advertising campaigns served on Twitter. To opt-out: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads

LinkedIn Pixel

These cookies measure ad conversions, optimise and build audiences for advertising campaigns served on LinkedIn. To opt-out: https://www.linkedin.com/legal/cookie-policy