Privacy Policy
Thank you for choosing Life in Cache. (“We”) are committed to protecting and respecting your privacy.
This policy (together with our Terms of Service and any other documents referred to on 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 and how we will treat it. By visiting www.lifeincache.com you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Life in Cache Limited of Kemp House, 160 City Road, London EC1V2NX, United Kingdom.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
Name or title of data privacy manager: I Holman
Email address: [email protected]
Postal address: Kemp House, 160 City Road, London EC1V2NX
You have the right to make a complaint at any time to the Information Commissioner’s 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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 17/10/2018.
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.
Third-party links
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.
Information we collect from 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 will collect and process the following personal data about you:
- Information you give us. This is information about you that you give us by filling in forms on our site www.lifeincache.com (our Site). The only information we collect is your first name, last name, and email address which is collected at registration and is only used by us to communicate with you where we need to. We do hold, protected by encryption, all the information you choose to store in your Life in Cache plan but this is only collected for use by you in building your personalised sections in our app [app.lifeincache.com] (our App) and is encrypted data which can only be seen by you and anyone you decide to share this information with. This information cannot be seen by anybody else including Life in Cache employees. If your Life in Cache account is managed by one of our business partners your first name, last name, email address, and date of birth (optional) are also collected and visible to authorised Life in Cache employees and your Life in Cache business partner account managers.
- Information we collect about you. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data including your user ID (your email address), browser content version, and whether you are an individual or a business user;
- Contact Data including your billing address, delivery address and email address;
- Technical Data including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), items you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any email addresses used to contact our customer service;
- Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 privacy notice.
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.
- Information we receive from other sources. This is information we receive about you if you use any of the other websites we partner with such as Stripe our payment gateway solution provider or the other services we provide. In this case we will have informed you when we collected that data if we intend to share the data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, resellers, sub-contractors in technical, payment and delivery services, Stripe (our payment solution provider), analytics providers (Google) and search information providers. We will notify you when we receive information about you from them and the purposes for which we intend to use that information. We will only use this data to allow us to supply the services described on our website. Your data is never shared with third parties without your consent.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good user experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.
Uses made of the information
We will only use your personal data when the law allows us to. We may use your personal data in the following circumstances:
- Information you give to us. We will use your account information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- 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.
If you are an existing customer or new customer, we will only contact you by electronic means (e-mail) to notify you about changes to our service or administer your account; or to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Purposes for which 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 lawful 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.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you for any information we may need |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) 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 |
(a) 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) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Explanation of lawful basis
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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
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.
Disclosure of your information
You agree that we have the right to share your account information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
We will disclose your account information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose only that information which we have collected about you and which we have access to, being your first name, last name, email address and telephone number (optional for 2-step verification) for individual account holders to the prospective seller or buyer of such business or assets.
- If Life in Cache Limited or substantially all of its assets are acquired by a third party, in which case your personal data held by it about its customers which we have access to will be one of the transferred assets.
- 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 Terms of Service and other agreements; or to protect the rights, property, or safety of Life in Cache Limited, our customers, or others but only to the extent to which we are legally obliged to disclose this data. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. In the event that any personal data is disclosed to third parties, they will only have access to the personal data which we hold which is not protected by encryption, which in this case, is your first name, last name, and email address. If your Life in Cache account is managed by one of our business partners your email address, first name, last name and date of birth are also collected and visible to authorised Life in Cache employees and your Life in Cache business partner account managers.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
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 or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Opting out
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 product/service purchase, warranty registration, product or service experience or other transactions.
Change of purpose
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.
Your private information
We appreciate that all of the private information which you upload to the Site is personal, confidential and of a highly sensitive nature. As such, we will never use your private information to gather information about you, to administer your account and we will never share any of your private information with any third parties. Your private information is safeguarded on our site and encrypted in such a way that it cannot be accessed by us. We can assist you in an emergency to try and help you login provided you have access to your passwords or your backup code. We do not have access to any of your passwords or backup code and this information cannot be retrieved by us.
Where we store your personal data
The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We take all steps reasonably necessary to ensure that your data is treated securely and protected to the fullest extent possible and in accordance with this privacy policy.
We operate the latest security technology ensuring your data is secure. Our databases consist of multiple segregated components. Each component is protected by a firewall and regularly updated antiviruses. All information contained within our databases has two levels of encryption using bank-level security. Your data is already AES-GCM encrypted in transit. The routes are protected by SSL using 2048-bit certificates. None of your data is stored in an open form. No encryption keys or access tokens are ever stored on our servers. All your data and the encryption keys are always separated so that if one or the other is compromised nobody will be able to find all the components.
Where you have chosen a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
As part of your account, you can choose to give trustees or professional advisers access to certain parts of your information including your private information for the purpose of administering your information. You should ensure that these parties are made aware of the importance of keeping your information private and secure and advise them that they should not share this information with any other person or persons without your express consent to do so. We will not be liable for any breach of your privacy or security by any person who has been given access to your account, including the sharing, use or appropriation of your private information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data by running the latest security technology, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to ensure as best we can unauthorised access.
As part of your account administration, you have the option to download some or all of your private information from the Site. You should be aware that, once any such information is downloaded, it will no longer be protected by the measures we have put in place to safeguard that information. You will then become solely responsible for the protection of that information and for ensuring there is no unauthorised access. The same applies to your Trustees and professional advisors who have access to certain parts or your entire information.
Retention of your information
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 at [email protected].
Deletion of your information
If you choose your cancel your account with us, all of your private information will be deleted immediately and will not be capable of being retrieved. If you fail to make a payment in accordance with our Terms of Use, your private information will be stored for a period of 60 days to allow you time to make any missing payments. If no payment has been received within this period, your private information may be permanently deleted and cannot be retrieved even if any missing payments are subsequently made.
Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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 restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) 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 you or to a third 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.
You can also exercise the rights set out above at any time by contacting us at Kemp House, 160 City Road, London EC1V2NX, United Kingdom OR [email protected]
Third party links
Our site may, from time to time, contain links to and from the websites of our partners and helpful information articles. 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.
Changes to our privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be emailed to [email protected]
Updated October 2018