Our commitment to you regarding your privacy
More Than Numbers Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Purpose of this privacy notice
This privacy notice aims to give you information on how More Than Numbers Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
More Than Numbers Ltd is the controller and responsible for your personal data (collectively referred to as More Than Numbers Ltd, 'we', 'us' or 'our' in this privacy notice).
If you have any questions about this privacy notice, including how we handle your personal data or any requests to exercise your legal rights, please contact us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This 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.
What data do we collect about you ?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
identity data - includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, passport number, unique tax reference (UTR), National Insurance number and personal information obtained from a credit reference agency in the course of confirming your identity.
contact data - includes company address, email address and telephone numbers.
transaction data - includes details about payments to and from you and other details of the services you use from us, and may include financial information obtained from a credit reference agency in the course of confirming your identity.
technical data - includes 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 use to access this website.
usage data - includes information about how you use our website, products and services.
profile data - includes your username and password, preferences, feedback and survey responses.
marketing and communications data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How do we collect your personal data ?
We use different methods to collect data from and about you including through:
direct interactions - you may give us your identity/contact data by filling in forms, corresponding with us by post, phone, email or otherwise, or face-to-face conversations and meetings. This includes personal data you provide when you:
apply for our products or services
subscribe to our service or publications
request marketing to be sent to you
enter a survey
give us some feedback
third parties or publicly available sources - we may receive personal data about you from various third parties, including technical data from the following parties:
analytics providers [such as Google based outside the EU]
advertising networks [such as Google based outside the EU]
search information providers [such as Google based outside the EU]
How do we use your personal data ?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
where we need to perform the contract we are about to enter into or have entered into with you.
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below 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 for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us 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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosing your personal details to others
We may have to share your personal data with the parties set out below for the purposes set out in the table in ' How do we use your personal data':
external third parties as set out in the Glossary.
third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.
How secure is the personal data I provide More Than Numbers Ltd ?
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.
Where we store and transfer your personal data
Your personal data is stored in the United Kingdom on our primary hard drive using full disk encryption (FDE) storage encryption technology that encrypts and secures all of your personal data at rest and can only be accessed using an authentication key. The same technology is used to store a mirror backup of your personal data on a secondary external hard drive in the United Kingdom.
Some of our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we will take steps to make sure that they provide a similar degree of protection in accordance with UK data protection law.
How long do we keep your personal data for ?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
Your legal rights
Under certain circumstances, by law you have the right to:
request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below). Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data about you, for example if you want us to establish its accuracy, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
request the transfer of your personal data to another party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you
withdraw consent at any time where we are relying on consent to process your personal data. 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.
If you wish to exercise any of the rights set out above, please contact us.
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 for access is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Your right to complain
You have the right to make a complaint at any time to the Information Commissioners Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
legitimate Interest - means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
performance of contract - means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
comply with a legal or regulatory obligation - means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External third parties
service providers [acting as processors] who provide IT and system administration services.
organisations [acting as processors or joint controllers] based in the United Kingdom who are contracted to provide the services which enable us to sell products and services.
professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based in the United Kingdom who require reporting of processing activities in certain circumstances.