Effective Date: 22/ 01/ 2013
The Company is registered under the Act with registration number Z3028214 and will act as the Data Controller.
This Policy (together with our Website Terms and Conditions of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data.
1 INFORMATION WE MAY COLLECT FROM YOU
1.1 We may collect and process the following data about you:
1.1.1 information that you may provide by filling in online forms and registration forms on the Site. This includes information provided at the time when you complete an online Service Marketing Request Form on our Site, or request further services. We may also ask you for information in the event you report a problem with our Site;
1.1.2 correspondence, or a record of it if you should contact us;
1.1.3 surveys that we use for research purposes, which we have asked you to complete, although you do not have to respond to them;
1.1.4 details of your visits to our Site (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access; and
1.1.5 information from third parties in respect of you which may include your employer, a referee or a person residing or working from another country.
2 IP ADDRESSES AND COOKIES
2.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
2.2 A “cookie” is a small electronic file that collects information when someone visits a website. A cookie can identify the pages that are being viewed, and this can assist us to select the pages that the viewer sees. Some cookies only exist whilst viewers are online, i.e. “session” cookies, but “persistent” cookies – which are not session-based – remain on the viewer’s computer, so that he or she can be recognised as a previous visitor when he or she next visits our website. We use “session” cookies to process your Service Request Marketing Form during a browser session. We use “persistent” cookies to gather statistical information about repeat usage from your computer or workstation
2.3 The Company may release browsing data and information gathered using cookies in the aggregate, such as publishing a report on trends in the usage of the Site. The report will only contain statistical data and will not identify any individual.
2.4 We do not store sensitive information such as account numbers or passwords in “persistent” cookies, and cookies in themselves, do not contain enough information to identify you. You will only acquire a personal identity in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined at 4 below.
2.5 In addition to using cookies, we might also use web tools to collect information about your browsing activities whilst on our Site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
2.6 Any information that we acquire about you using cookies or web tools is subject to the same restrictions and conditions as any other information we collect about you.
3 WHERE WE STORE YOUR PERSONAL DATA
3.1 All information you provide to us is, as far as reasonably practicable, stored on our secure servers to protect against the unauthorised access, use modification, destruction or disclosure of personal information. Any sensitive information, such as credit/debit card numbers will be encrypted using secure socket layer technology (SSL). We ask you not to permit anyone to use your name.
3.2 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 guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
3.3 We will retain your information securely stored for a reasonable period or for as long as the law requires.
4 HOW WE USE YOUR INFORMATION
4.1 We use information held about you in the following ways:
4.1.1 to process and submit your Service Request Marketing Form to credit broker, lenders and/or third party marketing partners (the “Advertising Partners”);
4.1.2 to provide you with the best possible service;
4.1.3 to ensure that content from our Site is presented in the most effective manner for you and for your computer; and
4.1.4 to notify you about changes to our products and services.
4.2 We use your data, or permit selected third parties to use your data, to provide you with data about goods and services which may be of interest to you, and we or they may contact you about these by post and e-mail. We may receive information from another lead provider/broker, namely any third party entity which provides services or information to customers regarding the availability and terms for short term loans and which provides us with information and customer lead generation.
4.3 As a US based business, it is sometimes necessary for the Company to transfer information held about you to the US. The eighth data protection principle of the Act restricts the transfer of personal data to a country outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects. In order to comply with this principle, the Company complies with the U.S. – E.U. Safe Harbour Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union member countries. Company has certified that it adheres to the Safe Harbour Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbour program, and to view Blue Global, LLC’s certification, please visit http://www.export.gov/safeharbor/.
4.4 We may contact you by post and e-mail with information about services similar to those which were the subject of a previous enquiry made by you.
4.5 If you do not wish to receive marketing communications from us OR our Advertising Partners offering goods or services which may be of interest to you, then do not submit a Service Request Marketing Form on the Site.
4.6 If you wish to opt-out of receipt of these marketing communications from us at any time you may do so by sending an email to us at [email protected] or by contacting us at Blue Global, LLC, 7144 E. Stetson Drive, Suite 300, Scottsdale, Arizona 85251, U.S.A.. Even after opting-out of our marketing communications, you may continue to receive marketing communications from Advertising Partners to whom already we have provided your Personal Information. You will be responsible for contacting those Advertising Partners directly to request that you receive no further marketing communications.
4.7 If you opt-out of our use of your data for marketing purposes, we will honour such choice once we have had a reasonable opportunity to process your request. We reserve the right to take reasonable steps to authenticate your identity with respect to any such request or other enquiry.
4.8 Any information or statistics relating to our business that we disclose to others shall not identify you personally. We may, for example, perform statistical analysis of the behaviour of the users of our Site in order to measure interest in the various areas of our site and to inform advertisers as to how many consumers have seen or “clicked” their advertising banners. This information, and any other general information about our users that we share with advertisers and other partners, will not disclose personal information about you.
5 DISCLOSURE OF YOUR INFORMATION
5.1 We may disclose your personal information to third parties:
5.1.1 To prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you.
5.1.2 If the Company or substantially all of its assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
5.1.3 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions of Use and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6 YOUR RIGHTS
6.1 Our Site may, from time to time, contain links to and from the websites of our advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
6.2 We will store and process your information on our computers and in any other way we consider appropriate. By “your information” we mean personal and financial information we (a) obtain from you or from third parties, such as credit reference agencies (who may search the Electoral Register), fraud prevention agencies or other organisations when you submit a Service Request Marketing Form which you give to us at any other time or (b) learn through the Service Request Marketing Form you submit through the Company.
6.3 We will use your information to provide our services, for research, assessment and analysis (including credit and/or behaviour scoring, market and product analysis) and to develop and improve our services to you and other customers and protect our interests.
6.4 Section 7 of the Act gives you the right to access information held about you. You can access, correct, update, amend, delete or remove information held about you in accordance with the Act by writing to us at [email protected] or Blue Global, LLC, 7144 E. Stetson Drive, Suite 300, Scottsdale, Arizona 85251, U.S.A. Any access request may be subject to a small statutory fee to meet our costs in providing you with details of the information we hold about you. We will respond to your request to access within 30 days.
6.5 Calls between us may be recorded and/or monitored.
6.6 If you were introduced to us by a third party, we will give them your contact details and sufficient information about you for their accounting and administration purposes.
6.7 We may give information about you and how you manage your account to the following:
6.7.1 people who provide a service to us or are acting as our agents on the understanding that they will keep the information confidential. If they are located in another country we will make sure that they agree to apply the same levels of protection as we are required to apply to information held in the UK and to use your information only for the purpose of providing the service to us;
6.7.2 anyone to whom we transfer or may transfer our rights and duties under this agreement;
6.7.3 we may also give out information about you if we have a duty to do so or if the law allows us to do so.
6.8 Otherwise we will keep information about you confidential.
7 CREDIT REFERENCE AND FRAUD PREVENTION AGENCIES
7.1 When you submit a Service Request Marketing Form you confirm that all the information you have given is true and complete. When you submit a Service Request Marketing Form you authorise our Advertising Partners to check the following records about you and others:
7.1.1 our own;
7.1.2 those at credit reference agencies (CRAs); and
7.1.3 those at fraud prevention agencies (FPAs).
7.2 Our Advertising Partners will make checks such as are deemed necessary to assess your application for credit.
7.3 If you tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
7.4 If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.
7.5 Law enforcement agencies may access and use this information.
7.6 We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
7.6.1 checking details on applications for credit and credit related or other facilities;
7.6.2 managing credit and credit related accounts or facilities;
7.6.3 recovering debt;
7.6.4 checking details on proposals and claims for all types of insurance; or
7.6.5 checking details of job applicants and employees.
7.7 We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
7.8 Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.