Privacy Policy

The protection of your personal information is important to us. We respect your privacy and want you to understand what we do with the information we hold about you. This privacy notice explains how we collect, use, share and protect your personal information. If we update this notice, we will post any changes on our website so that you will always know how your personal information is being used or shared.

Who is responsible for your data?

In this document “we” and “S&P” refer to Simpson-Partners Ltd. Simpson-Partners Ltd is the “data controller” for your personal data which means we have legal responsibility for how we collect and handle your data.

How to contact us

You can contact us in writing at: Simpson-Partners Ltd, Unit 8, Kemble Business Park, Malmesbury, Wilts, SN16 9SH Alternatively email us at [email protected] or send a message through the “contact us” page on our web site at https://simpson-partners.com/contact-us/

1 Your personal information

1.1 What is personal information and what is processing of personal information?

Personal information (or data) is any information relating to you and that alone or together with other pieces of information gives the person that collects and processes such information the opportunity to identify you as a person. It can be your name, some form of identification number, your location data, or information related to your physical, physiological, genetic, mental, economic, cultural, or social life.

Processing of the information means any action with your personal data, for example, collection, recording, organisation, structuring, storage, use or disclosure by any means.

1.2 What personal information do we collect?

We may collect the following types of personal information from you when you purchase or use S&P services or products:

• Contact details: information that allows us to contact you directly such as your name, email address, telephone number and addresses associated with your account or order
• Transaction information: records of the products and services you purchase from us
• Payment information: credit/debit card details and bank account details you provide to make payment for the products and services you purchase from us
• Delivery information: information relating to the delivery of our products to you
• Device information: information about the smartphones, mobiles, computers, or other electronic devices you connect to our products, website, or S&P app, such as details about the type of device (which can include unique device identifying numbers), its operating system, the browser you use and applications on the device that connect to our products and services. It can also include details of your internet service provider, mobile network
• Records of your discussions with our customer support teams when you share comments, opinions or ask us questions we will keep a record of this. We may also monitor and record our phone calls with you to make sure we are living up to the standards we want, as well as relevant laws and regulations
• How you use S&P products: we will collect information about how you are using S&P products and services and their performance
• How you use the S&P app and our website: when you use the S&P app or our website, we collect information about the pages you look at and how you use them
• Location information: we will collect information about your exact location when you choose to share that with us. For example, you may set up your S&P app to change settings when you are home, to do this you will need to share the location of your mobile device with us.
• You are not required to provide any of the personal information described above to us, however, if you do not do so, you may not be able to use our products and services, or the functionality of our products may be reduced.

1.3 What is personal information and what is processing of personal information?

Personal information (or data) is any information relating to you and that alone or together with other pieces of information gives the person that collects and processes such information the opportunity to identify you as a person. It can be your name, some form of identification number, your location data, or information related to your physical, physiological, genetic, mental, economic, cultural, or social life.

Processing of the information means any action with your personal data, for example, collection, recording, organisation, structuring, storage, use or disclosure by any means

1.4 What personal information do we collect?

We may collect the following types of personal information from you when you purchase or use S&P services or products:

• Contact details: information that allows us to contact you directly such as your name, email address, telephone number and addresses associated with your account or order
• Transaction information: records of the products and services you purchase from us
• Payment information: credit/debit card details and bank account details you provide to make payment for the products and services you purchase from us
• Delivery information: information relating to the delivery of our products to you
• Device information: information about the smartphones, mobiles, computers, or other electronic devices you connect to our products, website, or S&P app, such as details about the type of device (which can include unique device identifying numbers), its operating system, the browser you use and applications on the device that connect to our products and services. It can also include details of your internet service provider, mobile network
• Records of your discussions with our customer support teams when you share comments, opinions or ask us questions we will keep a record of this. We may also monitor and record our phone calls with you to make sure we are living up to the standards we want, as well as relevant laws and regulations
• How you use S&P products: we will collect information about how you are using S&P products and services and their performance
• How you use the S&P app and our website: when you use the S&P app or our website, we collect information about the pages you look at and how you use them
• Location information: we will collect information about your exact location when you choose to share that with us. For example, you may set up your S&P app to change settings when you are home, to do this you will need to share the location of your mobile device with us.

You are not required to provide any of the personal information described above to us, however, if you do not do so, you may not be able to use our products and services, or the functionality of our products may be reduced.

1.5 What do we use your personal information for?

It is important that you understand what we do with the data that we hold about you.

Purpose	Personal information used
Provide our services to you and maintain your account	All the personal information we collect (*)
Take payment for our products and services	Transaction and payment information
Deliver products to you	Delivery information
Answer your queries or complaints	All the personal information we collect (*)
Maintain and improve our products and services	All the personal information we collect (*)
Data analytics and statistical research to help us better understand how our products are used and make suggestions and recommendations to you about the use of our products	How you use our products How you use our apps and website Device information Transaction information Records of your discussions with our customer support teams
Staff training	All the personal information we collect (*)
Develop new products and services	All the personal information we collect (*)
Determine products and services that may be of interest to you	All the personal information we collect (*)
Direct marketing	Contact details, products, and services that we have determined may be of interest to you
Validating referral scheme applications	Contact details
Investigating misuse of your account, fraud, and debt collection	All the personal information we collect (*)

*Does not include your payment information

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site, apps and products and developing new products and services.

Personal information used

• Transaction and payment information
• Delivery information
• How you use our products
• How you use our apps and website
• Device information
• Transaction information
• Records of your discussions with our customer support teams
• Contact details, products, and services that we have determined may be of interest to you

1.6 How do we collect your personal data?

We will collect personal information from a number of sources. These include the following:

• Directly from you: for example, when you create your S&P account with us, purchase products from us, complete forms we provide to you, enter our competitions and promotions, contact us by phone, email or communicate with us directly in some other way
• Our website, app, and S&P products: provide us with information about how you use them and the devices in your home that you connect to them
• Other companies we work with provide us with information to help us deliver our products and services to you, and to understand you better
• Installers and service engineers: who will provide us with information about the installation and maintenance of S&P products.

1.7 How do we protect your personal information?

We take technical and organisational measures to ensure the personal information is processed in a manner that ensures appropriate security of information, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage. For example, we make sure that access to our systems containing personal information is only allowed to our employees if they have a genuine business reason for accessing that data.

Where we share personal information outside S&P, for instance as part of a research project, then the data is anonymised before it is shared with the project partners.

1.8 Who do we share your personal information with?

We share personal information with the following parties:

• Other companies’ apps and products: for the purpose of providing our apps, products & services
• Installers and service engineers: so that they can book appointments with you and provide installation and product maintenance services
• Delivery companies: to deliver products that you have ordered from us
• Other service providers and advisors: such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal or financial advice and help us deliver our services to you
• Market research: occasionally we may ask our market research partners to contact our customers to help us find out how to improve our products and services
• Third Party Partners: Where you have specifically allowed us to share your personal data with at this party, for instance, in order to take part in a research project or where you have agreed that you S&P products can be connected with another company’s products or services
• The Government or regulators: where we are required to do so by law or to assist with their investigations
• Police and law enforcement: to assist with the investigation and prevention of crime
• Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

We do not disclose personal information to anyone else except as detailed above. We may provide third parties with aggregate statistical information and analytics about users of our products and services, but we will make sure no one can be identified from this information before we disclose it.

Under no circumstances will we disclose data to third parties not specified here for advertising purposes.

1.9 Transferring your personal data internationally

The personal information we collect may be transferred to and stored in countries outside of the UK. Some of these jurisdictions require various levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the authority you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable European data protection laws and is respected and kept secure.

1.10 How long do we keep personal information?

We will keep your personal information for as long as you have an account with us. After you close your account with us, we will keep your personal information for a reasonable period to maintain our records and legal obligations to you.

2 Marketing

2.1 Direct Marketing

In accordance with the marketing preferences, you set when creating your account or that you set with us a later date, we may contact you by email, via the S&P app, text, mail, or phone with information about products and services we believe you may be interested in.

If you tell us not to email, send push notifications, mail, or phone you with direct market we won’t contact you in that way. You can let us know at any time that you do not wish to receive marketing messages by sending an email to us at [email protected]. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.

2.2 Advertising on other websites and apps

We work with our advertising agencies to show you advertising about our products and services on websites or apps that you visit, at a time and in manner that we feel is relevant to you. To do this, our advertising agencies use anonymised information about the websites, apps, social media content and ads you interact with or view when connected to the Internet, to make sure the advertising you see is more relevant to you. The techniques our advertising agencies use (to determine what advertising to show you), recognise the device you are using but are not aimed at you as a named individual. Typically, cookies and similar technologies are used to target this type of advertising.

3 Service notifications

The S&P app will send service notifications by email, or directly to your device through the app, when we have something important or interesting to make you aware of or you have asked to be notified about certain events relating to your S&P products.

4 Cookies

A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a web site’s computers and stored on your computer’s hard drive. You can configure your browser to be informed about the use of cookies and decide individually about their acceptance on a case-by-case basis or you can configure your browser to exclude cookies for certain cases. If you choose not to accept cookies, the functionality of our site may be reduced.

5 Your rights in relation to your personal information

You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you;
• the right to opt-out of receiving direct marketing messages;
• the right to request the correction of inaccurate personal information we hold about you; and
• the right to request the blocking or deletion of your personal information where the processing does not comply with applicable data protection laws.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out at the top of this notice.

If you are unhappy with any aspect of how we handle your personal data you also have the right to contact the Information Commissioner’s Office (ICO), the supervisory authority that regulates handling of personal information in the UK.

You can contact them by going to their website (https://ico.org.uk/), phoning them on 0303 123 1113 or by post to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

We are here to help and would encourage you to contact us first to resolve your complaint.