Privacy Policy

Privacy Policy

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 Policy (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 ("GDPR") and the Data Protection Act 2018.

For the purposes of this Privacy Policy 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 Policy.

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.

We do not attempt to collect special categories of personal data about you, or data relating to criminal offences or convictions. 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  However, it is possible that we will on occasion process special categories of personal data about you, where you expressly provide it (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 restaucomplaint which caters only for a specific religious group.  Please only submit data that constitutes special category data if you consent to us using the data for the purpose that you submit it, notably to pass the Complaint or compliment onto the company that you submit your comments about.

We may collect, use and share aggregated data such as statistical data for any purpose. Aggregated data may be derived from your personal data but does not directly or indirectly reveal your identity. 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 in accordance with this notice.

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 complaints or compliments 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 compliment or complaint and we follow up with you.]

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. Please see our Cookie Policy for further details.

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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To create your account on our Website

(a) Identity

(b) Contact

  • Performance of a contract with you and, after you terminate your account, we may need to retain your data on the basis of our legitimate interests, including internal governance and the potential for bringing or defending legal claims. 

To share your details with the company you have submitted a 'complaint' or 'compliment' about, so that they can provide a response

(a) Identity

(b) Contact

  • Performance of a contract with you [OR You have given consent to the processing of your personal data]

To manage our relationship with you, which will include:

(a) Answering your enquiries

(b) Notifying you about changes to our Website Terms and Conditions and/or Privacy Policy

(c) Asking you to leave a review or take a survey

(d) To send you marketing material, e.g. newsletters

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation

To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage and Tracking

  • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant and to develop our business)

 

Cookies

When you visit our Website, we place cookies on your computer or other device. For the most part, these cookies are used to enable the Website's functionality, improve the user experience or help us optimise our Website, measure traffic and other internal management purposes. You can find out more about our use of cookies, including how to reject cookies, in our Cookie Policy.

How we share your Personal Information

We may share your personal data with the parties set out below for the purposes set out in the table above.

 

The businesses you compliment or complaint about

We may share your details with the company you have submitted a 'complaint' or 'compliment' about, so that they can aim to rectify an issue or thank you for a compliment.

We may also consolidate data to be used in reports that we may sell or share with the consumer-facing businesses that have been complained or complimented about, but these reports will contain only aggregated data and no individual will be identifiable.

 

Trusted Third Parties

We may share your personal information with third parties who perform functions on our behalf and provide services to us such as:

  • professional advisors;
  • data analytics providers; and/or
  • IT consultants carrying out testing and development work on our business technology systems.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law, maintaining minimum standards of confidentiality. 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 in accordance with our instructions.

International Data Transfers

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

Data Security

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 hello@customerserviceaction.com 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.

The period for which third-party businesses, which you have complainted/complimentd about, will retain your data, such as email addresses, will vary and it is their responsibility as controllers of your data to notify you if they plan to retain your data on file in order to notify you about potential action in relation to your review, or to otherwise hold or use data for any other purpose.  It is the responsibility of the third-party business to provide you with a Privacy Notice explaining how they will process the data we provide to them, unless there is an exemption to their legal obligation to do so.

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 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 of correction or completion

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 or completed.  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.

While we are happy for such requests to be made, we are not able to guacomplaintee technical compatibility with a third-party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.

 

Right to withdraw consent

To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time.  You can do this by contacting us using the details in the Contact section  below. 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.

You can exercise any of the above rights by contacting us using any of the methods in the Contact section below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Most of the above rights are subject to limitations and exceptions.  We will provide reasons if we are unable to comply with any request for the exercise of your rights.

Complaints

If you are unhappy about our use of your personal information, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the below contact methods:

Telephone: 0303 123 11113

Website: https://ico.org.uk/concerns/

Post: Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

 

Other websites

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.


Internet-based transfers

Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. 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 guacomplaintee the security of your data transmitted to our Website via third party networks; 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.

 

Changes to our Privacy Policy

This Privacy Policy can be changed by Customer First Group at any time. If we change our privacy policy in the future, we will advise you of material changes or updates to our Privacy Policy by email.

 

Contact

If you have any enquires or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us by any of the methods below.

When you contact us, we will ask you to verify your identity.

 

Email: hello@customerserviceaction.com

Post: The Customer First Group

2nd Floor

Medius House

Sheraton Street 

London 

W1F 8BH

 

Our registered office is at:

It's All About the Customer Limited, t/a Customer First Group

160 Kemp House

City Road

London

EC1V 2NX