Privacy & Cookies Policy

1. What do you do with my personal data?

We use your data to provide you, and other Focus Finance users, great services. That includes doing things like:

Improving our products and services for you and other Focus Finance users including managing the e-magazine to ensure everyone gets the best experience, performing market research to understand our members views and personalising our experiences to make our service more intuitive & engaging;
Providing you with the products and services you have selected, keeping you up-to-date and informed and responding to your enquiries such as highlighting Focus Finance promotions and competitions we think you will be interested in;
Legal, regulatory or business reasons such as assisting with crime and fraud prevention and ensuring we provide the products and services you have selected.

We may use information about you to:

Improve our products and services

In line with industry best practice guidelines, we have a central database were we compile and hold all the information we have about our customers.

Enhance and personalise the products and services that we offer you and to develop new products and services;
Perform analysis and research and monitor usage behaviour;
Manage our e-magazine and your use of our e-magazine;
Aggregate information about you, your preferences and your use of the services with information about other users of the services in order to identify trends;
Analyse information about you including your browsing and location data on a personalised or aggregated basis.

Provide you with services and information

Provide you with the products and services you have selected and to manage your account with us;
Provide you with access to parts of this site;
Contact you if necessary;
Tell you about any new services or functionality (eg: the introduction of a new service or partner);
Market our products and services to you;
Send you information about our products and services by email or other means if you have opted in to receiving relevant marketing communications;
Send you information about products and services offered by other companies that we think you might be interested in if you have opted in to receiving relevant marketing communications.

Satisfy our legal, regulatory and business requirements

Help us keep your account safe, eg: checking your identity;
Investigate any complaints or other enquiries that you raise;
Assess credit risk, assess the provision of loans, debt tracing, debt recovery, credit management and crime, fraud and money laundering detection and prevention.

We may also disclose your personal information or information about your usage of our services to certain third parties. This data may identify you personally or may be included in aggregated and anonymised data (which means you will not be identified). These third parties may use this information:

To provide you with targeted Focus Finance or third party offers, promotions, adverts or commercial communications if you have opted in to receiving relevant marketing communications;
To give them a better understanding of our business; and/or;
To provide you with products and services or to improve the products or services you are already receiving. See "Who do you share my personal information with (and why)" for further details about the types of third parties your information may be disclosed to.

We are allowed to use your information in these ways because:

We need it to provide you with products and services and to manage your account with us;
We need to use some of your information to comply with legal and regulatory obligations
We have a legitimate business interest in some uses of your information (such as conducting market research); and/or;
You may have given your consent to us to use your data for certain activities, eg: marketing communications.

2. How long will you keep my personal data?

We keep information while you're our customer and after you've left us.

We use your information to provide you with the products and services you have selected and for a variety of other reasons.

For example, we might need to sort out disagreements, stop fraud and abuse, prove that you had an account with us or follow our legal obligations. Or the police may need it as evidence. We may also keep information about how you use our products or services.

In each case, the length of time that we need to keep the information may be different, but we will only keep the information for as long as we need it.

Law enforcement agencies are entitled to access this data in support of the investigation, detection and prosecution of serious crime.

3. Who do you share my personal data with and why?

We will share your information in the following situations:

With partners, suppliers, agents and subcontractors who help us deliver the products and services you've chosen to use;
When you have provided your consent;
When we have legal or regulatory requirements such as a request from the competition authority, law enforcement agency or a credit reference agency.

We may share your information:

With our current and prospective partners, agents and subcontractors (for example, advertisers and content providers) who are involved in delivering products or services used or ordered by you;
With other companies in the Focus Finance group, including their respective partners, agents and sub-contractors;
With any relevant public authority or law enforcement agency;
With any debt collection agency or credit reference agency;
Where there is a change (or prospective change) in the ownership of Focus Finance to new or prospective owners. In these circumstances we would require them to keep it confidential;
Where we (or an affiliate processing your data on our behalf) are required to do so by law, regulation or legal proceedings;
Where we believe it is necessary to protect Focus Finance or third-party rights and property;
Where you give us false or inaccurate information and/or we identify or suspect fraud;
In response to a valid, legally compliant request by a competent authority;
During emergencies when we believe physical safety is at risk;
In response to a complaint that you have breached the services terms & conditions or any other product or service terms.
Further to the above disclosures, the data we collect using your browsing pattern may be sold (or otherwise passed on) to our clients and carefully selected third parties. However, we do not disclose individual information to them, but only aggregated and generalised information.
By entering your information into this site, you agree that valued third party partners may contact you via telephone, automated telephone, email, SMS, post or other appropriate means, with new interesting products and services offers, who may be in a position to help you. You should always read their terms and conditions.
We may pass your details onto third parties for marketing of products and services that they feel may be of interest to you. The following sectors are the industry types you can expect to receive 3rd party products, information, services or special offers from - Automotive, Call Centre, Network Providers, Claims, Competition Sites, Finance, Freebie Sites, Funeral Plans, Gambling, Insurance (Life, Home, Automotive, General, Private Medical, Travel), Lottery, Pension, PPI, and Utilities. We may also supply your data to these sectors via agencies/brokers.
Third parties include, but are not limited to:

Services Provided	Company Details
Utilities	Love Energy, EDF Energy, Plusnet Broadband, BT Broadband, Virgin Media, SKY, NOW TV, NOW TV ROI, Metrophone
Subscription Service	Focus Finance Trading name of Chambers Clarke LTD, Gourmet Society
Network Providers	Network Three (3), O2 (Telefonica), Vodafone Ltd,
Survey/Sales Call Centres	O2
Debt Management/Finance	Money Information Group LTD, Get Me Car Finance, Money Tree Media Ltd - Short Term Lending (Credit Broker) - SMS Email Telephone
Credit Broker	Trusted Finance Ltd
Affiliate Marketing	Advortis - through subscription service if you wish to use any product. Money Tree Media Ltd Vouchers and Promotions - SMS Email Telephone Advortis Marketing new Media 258 Merton Road SW18 5JL London
Credit Ref Agency	Experian
Loan Broker	Company Name: Mediablanket Ltd Company Address: The Old Bank, 247 Chapel Street, Salford, M3 5EP Company Reference Number: 723605 Trading Names: https://loans-247.co.uk/ https://www.autodosh.co.uk/ https://supacompare.com/homeowner
Shopping	Sava Point, Metrofone, Top Cash Back
Data Broker	www.finance4ugroup.co.uk
Insurance	Travel Insurance 4 Medical, 247 Home Rescue, Pedal sure
Funeral Plans	Pride Planning, Safe Hands Funeral Planning
Comparison	Helpyourmoney.net trading name of Chambers Clarke LTD, Energyhelpline.com trading name of Fund Raising Innovations, Compare The Market

We endeavour to update this on a quarterly basis.

We may also pass your information to the ICO and/or other regulatory/governing bodies, for the purposes of compliance monitoring.

4. What data do you hold about me? (and how do you get it?)

We collect information in three ways:

Directly from you, such as information filled in within application or registration forms.
From the products and services you use, such as the pages you visit on the Focus Finance website, your browsing history including the e-magazine editions you view and your location data;
From 3rd parties, such as information from credit reference agencies and fraud protection agencies and data brokers

We collect such information as:

Your contact information including name, address, email address and telephone number;
Your order history including;
Your payment details including debit or credit card details, banking details and Paypal details;
Your account
Your communications with us including requests and complaints;
Your activity/interactions on our website;
Your data and Internet Protocol (IP) address;
Your use of our services

How we collect information:

We collect information directly from you when you are asked to provide personal details about yourself, including but not limited to when you:

Purchase products or services from us;
Register to become a Focus Finance customer;
Submit enquiries or comments to us or contact us;
Enter any promotions, competitions or prize draws via the services;
Use any Focus Finance products and services (including where you participate in the Focus Finance community by posting on our Blogs and Forums);
Take part in market research; and/or;
When you make changes to or terminate your account with us.

We collect information about you indirectly:

When you use any Focus Finance products and services
From third parties including but not limited to those who provide our financial services, take payments and manage product orders and dispatch;
We may also collect information about you from other sources, including but not limited to: credit reference agencies, fraud prevention agencies and business directories and other commercially or publicly available sources;
Our website uses a website recording service which records mouse clicks, mouse movements and page scrolling. Data collected by this service is used to improve our website usability. The information collected is stored and anonymised and then used for aggregated and statistical reporting. You will not be personally identified;
We use cookies and similar technologies to provide us with information about your usage of our website, to support our functionality and to give you the best possible on-line experience. Read our Cookie Policy to learn more.

5. What rights do I have?

You have the following rights:

To be informed about how we use your personal data (the purpose of this Privacy Notice);
To update your personal data. You can update or amend your information by logging in to your account on the section of my billing information. For data not updateable through y billing information, you will need to contact us;
To ask us to delete your personal data. However, there may be circumstances where we are legally entitled to retain it;
To get a free copy of your personal data. A subset of your data (limited to data that you have provided to us) is available in a machine-readable format if required;
To object to the processing of your data and have it restricted. There may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse that request;
To review some automated decision-making or profiling (automated processing to determine certain things about you);
The right to make a complaint to the Information Commissioner (www.ico.org.uk) if you think that any of your rights have been infringed by us.

To exercise any of your rights, you will need to contact our customer support team. You will need to provide the following information so that we can verify your identity:

a colour copy of the account holder's passport driving licence, birth certificate or utility bill;

Focus Finance are required to respond to your request within 1 month. Where requests are complex and excessive, Focus Finance is permitted an additional 2 months to process your request. However, in these circumstances we would provide an update on your request within 1 month it.

When requesting a copy of your personal data, you can also do this via datacontroller@focusfinance.co.uk.

Focus Finance reserve the right to charge an admin fee or refuse a request where requests for data are clearly unreasonable or excessive, particularly if they are repetitive.

6. How do I change my marketing preferences?

You can opt in and out of marketing communications at any time by changing your preferences within my preferences after logging into your account. You will be able to choose to receive marketing communications about the products and services you have chosen, all marketing communications from Focus Finance or options from selected partners.

You can also opt out of marketing communications by following unsubscribe links at the bottom of any marketing emails received from Chambers Clarke LTD/Focus Finance/Smart Connexions/helpyourmoney.net

We will never give your personal data to a third party for marketing unless you have expressly given us your permission.

7. How do you ensure my data is secure?

Focus Finance is committed to keeping your data secure. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. In order to protect your personal data, we have strict security measures in place:

We use secure cloud servers to store your data. These are treated as confidential and are not accessible to the public
The data is only accessible (by means of user log in and password credentials) to those of our own employees or those third parties who need to know such information in order to deliver our products and services
In order to identify security threats, and to ensure continued security, Chambers Clarke LTD routinely evaluates its data security procedures.

We will not store your personal details beyond the legally-permitted period and so records we hold relating to you will be entirely deleted from our servers at the point we can no longer legally retain them.

Security of Communications

Please be aware that communications over the Internet, such as e-mails and webmail's, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered - this is the nature of the World Wide Web/Internet. Focus Finance cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

Third Party Sites

This policy does not apply to third party sites that you may access via our website. You should therefore ensure that you are familiar with the applicable third-party privacy policy before entering any personal information on a third party site.

This policy does not apply to third party sites operated by those promoting Focus Finance. You should, therefore, review relevant policies to learn about how your personal data will be treated.

Non-EEA Use of Information

The information you provide to us may be passed to third parties located outside the European Economic Area. Countries outside the European Economic Area do not always have strong data protection laws. However, we will always take steps to ensure that your information is used by third parties in accordance with this policy. This can be done in a number of different ways, for instance:

The country that we send the data to might be approved by the European Commission;
The recipient company might have signed up to a contract obliging them to protect your information; or;
The recipient is located in the US and is a certified member of the EU-US Privacy Shield scheme.

In other circumstances the law may permit us to otherwise transfer your information outside the EEA. In all cases, however, we will ensure that any transfer of your information is compliant with data protection law.

You can obtain more details of the protection given to your information when it is transferred outside the EEA contacting us.

8. What else can I do to ensure my data is secure?

Along with a section on Privacy, Get Safe Online has plenty of other good advice about protecting yourself online

9. How can I contact you?

If you would like more information or would like to raise any queries with us in relation to your information, you can contact us by writing to the Data Protection Officer at:

Data Protection Officer

Focus Finance

109 Cheetham Hill Road

Manchester

M8 8PY

10. Changes to this Privacy Notice

We will check this policy from time to time and post any changes here.

We may also let you know about these changes by email, voicemail or text

11. Resolving Privacy Issues

We will always try our best to resolve any data privacy issue you may have. You have the right to refer any data privacy issue to the Information Commissioner's Office at any time.