It's All About the Customer Limited (a company registered in England with company number 10782184), trading as Customer First Group ("Customer First Group", “we”, “us” or “our") is committed to protecting the privacy of the users of our website, Customer Service Action ("Website"). We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect via various channels (including our Website and through e-mail), is only used for the purposes set out in this policy.
References in this notice to “you" or “your” are references to individuals who use the Website and/or create an account.
Through this Privacy Notice (together with our Website Terms and Conditions) we aim to inform you about the types of personal data we collect from you, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 ("EU-GDPR"), the UK-GDPR and the Data Protection Act 2018.
For the purposes of this Privacy Notice the controller of personal data is Customer First Group and our contact details are set out in the Contact section at the end of this Privacy Notice.
We do not knowingly collect personal information from children under 16 years of age. If you are under 16 years old, please do not provide any personal information to us.
The Information we collect
We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us. These terms are used throughout this notice:
Identity Data: including your first name, last name, username or similar identifier, title;
Contact Data: including your email address and telephone numbers;
Marketing and Communications Data: including your marketing and communication preferences. We also track when you receive and read marketing communications from us, which information we use to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials. Additional information about the personal data we process in connection with marketing is included with the marketing communications we send you;
Profile Data: including information collected progressively when you visit our Website including your referral website, pages you visit, actions you take, patterns of page visits and information from forms you fill in;
Technical Data: including information collected when you access our Website, such as your 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 are using; and
Usage and Tracking Data: information about how you use our Website.
Special Category Data: includes personal data relating to health, race or ethnic origin, religious or political beliefs, political opinions, sex life or sexual orientation, trade union membership.
We do not attempt to collect special categories of personal data about you, or data relating to criminal offences or convictions. However, it is possible that on occasion you may supply special categories of personal data about you, e.g., such as where you complain about a physical reaction to a product you purchased, or when this is inferred from data you provide to us, e.g. if you provide a review upon visiting a restaurant which caters only for a specific religious group. We do not intentionally process data to infer details that fall within special categories of personal data.
Where we receive unrequested special categories of personal data, we may delete it from our systems.
We may collect, use and share anonymised and aggregated data such as statistical data for any purpose. Anonymised and aggregated data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may anonymise the total company score data in order to display the metrics you can see on the Website, create and share reports with anonymised and aggregated data from Customer Experiences based on submissions to the Website, or aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.
How your Personal Data is collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you create an account on our Website, give us feedback or contact us, or request marketing to be sent to you.
[We may obtain further personal information about you during the course of our relationship with you, for example when a business responds to your Customer Experience and we follow up with you.]
How we 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 on the basis of more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details further down this page 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.
International Data Transfers
We do not transfer your personal data outside of the UK or European Economic Area (EEA).
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.
How long we will hold your information for
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint to us or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
We conduct regular data cleansing and updating exercises to ensure that (a) the data that we hold is accurate, and (b) we are not holding data for too long.
In some circumstances you can ask us to delete your data by emailing us at firstname.lastname@example.org and requesting deletion of your account — see the section below on your legal rights for further information.
We might anonymise your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.
Where you choose to share information with a third-party business, we will make sure you are signposted to their T&Cs and privacy notice.
Your rights on Information we hold about you
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Right to be informed
This relates to what information we are required to provide you about data processing. This Privacy Notice provides this information.
Right of access
You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the data protection legislation permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
Right to Rectification
If personal information 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. You can let us know by contacting us using the details listed further down this page.
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, or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to object to or restrict processing
In certain circumstances, you have the right to object to our processing of your personal information by contacting us using the details further down this page. 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. You also have the right to object to use of your personal information for direct marketing purposes.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period when we are verifying its accuracy.
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.
You can ask us to transmit that information to you or directly to a third-party organisation.
The above right exists only in respect of personal information that:
you have provided to us previously; and
is processed by us using automated means.