Refundee’s
Privacy Policy

Everyone

Marketing

We use marketing to let you know about our services offered as well as any other services which may be of interest to you, including developments that could have an impact on the original service you engaged with us on, new claim areas, and/or similar services.

Should you no longer wish to receive information about similar products and services, you can always object to receiving marketing communications from us and we’ll stop processing your data for marketing purposes. You’re able to withdraw your consent verbally via telephone or in writing via email or post using the contact details at the start of this policy.

We may use your personal information, including information about how you interact with communications we send to make decisions about what services we think you may be interested in and tailor our marketing communications to you. This is called profiling for marketing purposes. We believe we have a legitimate interest to do this and that it is not against your rights. However, if you don’t want us to use your personal information in this way you have a right to object to this and can let us know using the contact details at the start of this policy.

What data do we collect

We’ll only collect information that we genuinely need to meet or perform the legal or contractual obligations necessary to provide you with our services, where we have a legitimate interest to do so, or where we have your permission (your consent). This will likely include the collection of:

• information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit and number of page views).

• information relating to any transactions carried out between you and us on or in relation to our website, including information relating to the supply of our Claims Management Services.

• information that you provide to us for the purpose of registering with us (including name, address, telephone number, email address, details of the claim including loss amount and any financial information relevant to your claim).

• information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters.

• information required to complete our Claims Management Services that we’ll request directly from you, including your personal circumstances. 

• information to help us to better understand you and provide you with information about other services which may be suitable and relevant. For example, information about how you interact with electronic communications we send, such as email and text message (SMS).

• any other information that you choose to send to us.

Recipients of your data

We control the use of your data in line with this policy and we don't sell your data to third parties in any circumstances.

So that we can effectively provide our Claims Management Services to you, we’ll share your data with third parties relevant to your claims that provide critical functions in accordance with strict data security arrangements:

• Our Claims Management Services: While providing you with Claims Management Services we’ll provide your data, under your specific instruction, to banks / financial services organisations relevant to your claim, any third party named by you as being relevant to your claim (such as building companies, conveyancers etc) and, if required, the Financial Ombudsman Service. 

• Our Advertising: we use any third party advertising representatives to design, host and manage our advertisements on platforms such as Facebook, Google ads and others. They’ll set cookies on your device in accordance with our cookie policy. 

• Our Systems and IT: we use third party firms who provide essential storage arrangements (including call recordings), software and support to our infrastructure some of which are stored outside of the European Economic Area (EEA).

• Communicating with you: we may use an outsourced print-house to manage our printing, they would receive a copy of postal communication to print and send this on our behalf. 

• Our Regulators: we may be required to provide your data to our Regulators, who include the Financial Conduct Authority, the Financial Ombudsman Service and the Information Commissioner’s Office.

• Our Professional Services: we use professional legal, consultancy and accountancy services to help us fulfil our legal obligations and help us improve our business.

• Other Third Parties: we may share your data with other third parties that provide services to us where you provide consent or we believe we have a Legitimate Interest to do so, including review platforms, tracing agents, credit controllers and/or debt collectors.

We’ve carefully selected our third parties due to their commitment to keeping your data safe. If you request for us to stop processing your data, we’ll also communicate this to the relevant third parties if they’re processing this on our behalf. If you have any concerns about the above third parties, please let us know and we can provide advice and support to help you manage your data preferences.

Your data rights

As a data controller, if you request the rectification, erasure or restriction of your data, we’ll also communicate this to any third party who your data has been disclosed to.

In exercising any of your rights, we’ll take action within one month. However, should the request be complex we can extend this by a further two months. We’ll inform you of this in this event. We’ll need to confirm your identity before completing any action on your behalf, and reserve the right to not complete action until we are satisfied that you are making the request. If we cannot complete your request, we’ll inform you within one month and explain why.

Data Access

You can access your data at any time by submitting a Subject Access Request (SAR). We’ll confirm what data is being processed and provide you with a copy of your data in addition to confirming your data rights for free. However, if you make repetitive requests, we’ll charge an administrative fee of £10.

You can make this request using reasonable means, including by telephone, post or email. If you make the request by email, we’ll provide your information in a commonly used electronic format unless you instruct us otherwise.

Data Rectification

You can amend any inaccurate data that we hold by notifying us by telephone, post or email, or during the course of the provision of our services. We’ll make the amendment as soon as possible. If any data held is incomplete, you can complete this at any time. We may require this to be completed to allow us to provide our Claims Management Services.

Data Erasure

At your request we can erase or “forget” your data in the following situations:

• We no longer require your data (when we have finished providing any Claims Management Services requested by you and are no longer subject to any legal or Regulatory requirements, such as accounting requirements and complaints handling);

• You withdraw your consent and there is no other reason for us to hold your data;

• You object to the processing, as described below;

• You believe your data has been unlawfully processed; or

• There is a legal obligation to erase your data.

You can make this request using reasonable means including by telephone, post or email. If you request for your data to be erased, we’ll confirm whether this can take place and the next steps that we’ll take. If we cannot erase your data, we’ll explain why and confirm any actions required to allow us to do so.

Data Restriction

At your request you can restrict us from processing your data in the following situations:

• You believe your data is inaccurate;

• You believe your data has been unlawfully processed but do not want us to delete your data;

• We no longer need your data but it is required by you for making or defending a legal claim; or

• You object to the processing, as described below, but we’re verifying this.

If you make a restriction request, we’ll still store a copy of your data but cannot use this. We’ll inform you if the restriction needs to be lifted. You can make this request using reasonable means including by telephone, post or email. If you request for your data to be restricted, we’ll confirm whether this can take place and the next steps that we’ll take. If we cannot restrict your data, we’ll explain why and confirm any actions required to allow us to do so.

Object to data processing

You can object to the processing of your data at any time. If you object, we’ll no longer process your data unless we have a compelling and legitimate reason not to do so. In this case, you’ll be informed why we can’t stop processing your data. In the event that you do this while we are providing Claims Management Services to you, it is possible that we won’t be able to continue with your claim. If this is the case our fee may still be applicable at a later date.

You can always object to receiving marketing from us and we’ll stop processing your data for marketing purposes at any time.

You also have the right to object to us using information about you and how you interact with our services to tailor our communications to you.

You can exercise your right to object to the processing of your data using the contact details at the start of this policy.

Data Portability

We can provide your data in a commonly used electronic format at your request. We can also transfer this to another entity or person where we’re processing your data with your consent or in accordance with a contract. This only applies to information processed by automated means. 

Legal & Regulatory Requirements

We have regulatory requirements and other legal requirements that may require us to use your data. This includes things such as complaint handling and financial record keeping. In these circumstances we may be required to keep your data by law and we’ll inform you if this is the case.

Cookies

Our cookie policy can be found here.

A cookie consists of information sent by a web server to a web server and is stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web server.

Disclosures

We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this policy.

In addition, we may disclose information about you:

• to the extent that we’re required to do so by law;

• in connection with any legal proceedings or prospective legal proceedings; and

• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Third Party Data Transfers

We may transfer and store the data we collect from you to organisations outside the European Economic Area (EEA). This would be where we have your consent, to comply with a legal duty or where we work with a third party to provide you with our Claims Management Services and they process information outside the EEA. 

Where we do this, we’ll make sure that your data is protected to the same extent as in the EEA.

Third Party Websites

This policy references other websites. We’re not responsible for the privacy policies or practices of third party websites.

Complaints

If you have a complaint about how we use your personal information, you can contact us via telephone, through live chat on our website or by filling in a contact us form on our website and we’ll do our best to fix the problem. This is also how you can also reach our Data Protection Officer.

If you’re still not happy with our response, you can refer your complaint with a data protection supervisory authority in the EU country where you live or work, or where you think a breach has happened. The UK’s supervisory authority is the Information Commissioner’s Office (ICO). For more details, you can visit their website at ico.org.uk.

Updates to this policy

We’ll post any changes to this privacy policy on this page and if they’re significant we’ll let you know by email.