Parent Page: Privacy
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Updated: 5 November 2024
PCS is committed to protecting your data and respecting your privacy.
Introduction
This Privacy & Data Protection Statement (“Privacy Statement”) describes how PCS collects, uses, shares or otherwise processes information relating to individuals (“Personal Data”) and the rights associated with that processing.
A reference to “PCS”, “we,” “us” or the “Company” is a reference to PCS and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Data.
PCS respects your privacy and is committed to protecting your Personal Data. This Privacy Statement will inform you as to how we look after your Personal Data (i) when you visit our websites including https://personcentredsoftware.com (regardless of where you visit it from); or (ii) when sending us an email or otherwise when communicating with us; (iii) when you interact with us such as when you (whether for yourself or on behalf of the organisation you work for) purchase products and services from us or supply products and services to us; (iv) when you visit our premises and will tell you about your privacy rights and how the law protects you.
This Privacy Statement contains the following sections. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Statement.
1. Important information and who we are
Purpose of this Privacy Statement
This Privacy Statement aims to give you information on how PCS collects and processes your Personal Data:
- through your use of this website, including any data you may provide through this website;
- when we otherwise communicate or meet with you, including communication by email or other media; and
- when you attend our premises and events.
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 Statement together with any other privacy statement or policy or fair processing policy 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 Statement supplements other notices and privacy policies and is not intended to override them.
The US & Canada Privacy Annex provides additional provisions in relation to processing of Personal Data of data subjected located in those jurisdictions.
This Privacy Statement is not applicable to Personal Data we collect and process in respect of our personnel or individuals who apply for roles with us as part of our recruitment activities. We will collect and process such Personal Data in accordance with separate privacy notices.
When we refer to ‘your organisation’ in this Privacy Statement, we are referring to your employer or organisation you work for.
Controller
PCS is the data controller in respect of data collected through its websites and in other ways and is responsible for your Personal Data as set out in this Privacy Statement.
Processor
Please note that where we provide services to a customer, PCS is the data processor, and the customer is the data controller of any third-party Personal Data the customer provides to us (such as Personal Data of a care resident) to enable us to provide certain features of our services (“Third-Party Data”).
We use Third-Party Data to provide the services to our customers under our agreement with customers. In addition, we may use such Third-Party Data to derive anonymous data for research and benchmarking purposes, analysing and improving the services, as well as preparing aggregated reports and statistics.
The data processing provisions governing our use of the Third-Party Data and our duties as a data processor will be included in the terms of our agreement with each customer. The customer is responsible for informing the residents (service users) and staff within a home (location) about the use of Third-Party Data and the customer shall not input, upload, provide or otherwise make available to or through the services any Third-Party Data unless the customer has a legal right to this use.
For the compliance with some privacy laws for non-European territories including Australia please see the details of that processing in our Product Privacy Annex
Contact details
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Statement. If you have any questions about this Privacy Statement or our privacy practices, including any requests to exercise your legal rights or complaints regarding the compliance with applicable privacy laws, please contact the Data Protection Officer using the details set out below.
For United Kingdom & Europe
Full name of legal entity: Person Centred Software Limited
Email address: dataprotection@personcentredsoftware.com
Postal address:
Saxon House
3 Onslow Street
Guildford
Surrey
GU1 4SY
England, United Kingdom
For Australia and New Zealand:
Full name of legal entity: Person Centred Software (Aust) Pty Limited
Email address: dataprotection@personcentredsoftware.com
Postal address:
Suite 9, Level 2
12 Pirie Street
Adelaide
SA 5000
For United States and Canada:
Full name of legal entity: ResHub Healthcare Inc.
Email address: dataprotection@personcentredsoftware.com
Postal address:
8 The Green
Suite R
Dover
DE, 19901
United States
In United Kingdom, 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.
In European Economic Area, United States and Canada, you have the right to make a complaint to your respective local data protection regulator.
In Australia, if you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner: by phone (1300 363 992), post (GPO Box 5218, Sydney NSW 2001) or email enquiries@oaic.gov.au
Changes to the Privacy Statement and your obligation to inform us of changes
We keep our Privacy Statement under regular review. This version was last updated in October 2024 and it will be updated by posting an updated version on our website. Please check regularly for the updated version.
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. Please use the contact details above.
Third-party links
This website and other communications may include links or references 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 or polices. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal Data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. 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 name, username or similar identifier, title and your image on CCTV (if you visit our premises) and on recordings of meetings on internet meeting platforms.
- Contact Data includes address, email address and telephone number.
- 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 or our services.
- Profile Data includes your username and password, purchases or orders made by you or us, your preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing materials from us and our third parties and your communication preferences.
If you are an individual customer or supplier (where you act in your personal capacity and not on behalf your employer or other organisation), we may also collect, use, store and transfer the following additional kinds of Personal Data about you:
- Financial Data includes bank account and payment card details.
- Transactional Data includes details about payments to and from you and other details of products and services you have purchased from or supplied to us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not relate to and identify you anymore. 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 you can be identified from the data, we treat the combined data as Personal Data which will be used in accordance with this Privacy Statement.
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.
If you fail to provide Personal Data
Where we need to collect Personal Data by law or under the terms of a contract we have with you or your organisation, 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 or your organisation (for example, to provide you or your organisation with products or services). In this case, we may have to cancel a product or service you or your organisation have with us but we will notify you or your organisation if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial Data and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, through our website or social media accounts or otherwise. This includes Personal Data you provide when you or your organisation:
- purchase our products or services;
- sell your products or services to us;
- subscribe to our publications;
- post messages or participate in discussions through our social media accounts;
- request marketing to be sent to you;
- enter a promotion or participate in a survey;
- give us feedback or contact us; or
- administer and/or manage any interaction, relationship or contract between you or the organisation you work for and us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
- Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources such as:
- Technical Data from the following parties:
- analytics providers such as Google (further information can be found here: https://policies.google.com/technologies/partner-sites)
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK or EU.
- Technical Data from the following parties:
- Visitors to our premises. We will collect and process Identity and Contact Data when you visit our premises for our visitor records and primarily for security and safety reasons.
- Use of our Wi-Fi network. We may collect and process Technical and Usage data when you use our Wi-Fi network.
Telephone recordings. We may record your phone call or Teams/Skype/Zoom meetings or similar platforms for training purposes, to ensure quality customer service and/or to provide a permanent record of the call or meeting.
4. How 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 or your organisation.
- 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 obligation.
See the Glossary to find out more about the types of lawful basis that we will rely on to process your Personal Data.
Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will obtain your consent before sending marketing communications to you via mail, email or text message. You have the right to withdraw consent to marketing communication at any time by contacting us using the contact details above.
Purposes for which we use your Personal Data
When collecting and using Personal Data, our policy is to be transparent about why and how we process Personal Data. We have set out below a description of all the ways we may 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 basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your Personal Data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you or your organisation as a new customer |
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Performance of a contract with you or your organisation. |
| To provide products/services to you or your organisation |
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| To purchase products/services from you or your organisation |
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| To process and deliver you or your organisation’s order including: 1. Manage payments, fees and charges 2. Collect and recover money owed to us |
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| To manage our relationship with you or your organisation which will include: - Notifying you about changes to our terms or Privacy Statement - Asking you to leave a review or take a survey - Asking to provide feedback or comment in connection with your use of our website or products and services - Providing you with information about the products/services we provide to you or your organisation, including changes to our products or services |
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| To enable you to complete a survey |
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| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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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 operate interactions such as forms and flows in regard to the product/service you or your organisation operates with us |
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| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
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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 you of our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you or your organisation |
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Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To manage our business contact list |
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Necessary for our legitimate interests (to develop our products/services and grow our business) |
| By using the names and other Personal Data of representatives of corporate customers and suppliers in order to manage our interactions with those customers and suppliers |
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| By using the names and contact details of individuals who are our suppliers |
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| For security purposes |
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Necessary for our legitimate interests (to ensure the safety of our staff, premises and visitors to our premises) |
| To provide Wi-Fi access |
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Necessary for our legitimate interests (to provide you with access to the internet) |
| To record your phone call or Teams or similar platform meetings for training purposes, to ensure quality customer service and/or to provide a permanent record of the call or meeting |
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| To communicate with you or your organisation generally |
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| To enable you to access certain services provided to our customers |
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| To comply with our legal obligations including the prevention of financial crime |
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To comply with a legal obligation |
Marketing
With your permission and/or where permitted by applicable law, we may also use your Personal Data for marketing purposes, which may include contacting you by email, telephone, text message and/or post with information, news, and offers on our products and services. We will always work to fully protect your rights and comply with our obligations under the UK GDPR or EU GDPR (as applicable) and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out; see below. You will not be sent any unlawful marketing or spam.
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 goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes and you will be able to opt-out at any time.
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 prevent us using your Personal Data to contact you for other than marketing purposes (e.g. where we need to contact you or your organisation in connection with your or your organisation’s purchase or use of our products/services and your or your organisation’s contract with us).
Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie policy available here.
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 require further information 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 or a regulator.
5. Disclosure of your personal data
We may share your Personal Data with the parties set out below for the purposes set out in the table Purposes for which we will use your Personal Data above:
- Companies that are part of our corporate group.
- 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 Statement.
All Personal Data will only be transferred where there is a need to do so (for use in the course of providing services to us or you or your organisation) and these third parties will also be subject to agreements regarding the handling and use of your data.
We require all third parties to respect the security and confidentiality of your Personal Data and to treat it in accordance with the law. We do not allow these third parties 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.
In some limited circumstances, we may be legally required to share certain Personal Data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, the rules of any applicable stock exchange, or the instructions of a government authority or recognised regulator.
6. International transfer
Generally, we will store your Personal Data in the United Kingdom or European Union (as the case may be), and for Australian and New Zealand customers also in Australia.
Transfers of Personal Data between the United Kingdom and European Union are currently permitted without additional safeguards.
However, some of our External Third Parties may be based or have servers outside the United Kingdom or European Union so their processing of your Personal Data may involve a transfer of data outside the United Kingdom or European Union (as the case may be).
Whenever we transfer your Personal Data out of the United Kingdom or European Union, we do our best to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the UK Supervisory Authority or EU Supervisory Authority (as the case may be).
- Where we use certain service providers, we may use specific contracts, model contractual clauses or certification methods approved by the UK Supervisory Authority or European Union (as the case may be) and which give Personal Data the same protection it has in the United Kingdom or European Union (as the case may be).
Similarly, we comply with our legal obligations when we transfer the data outside of Australia and other jurisdictions where privacy law applies.
Please contact us if you require further information on the specific mechanism used by us when transferring your Personal Data out of the United Kingdom, EEA or other jurisdiction.
If any of the above safeguards or mechanisms are not available or implemented for a specific transfer outside the United Kingdom, we will obtain your explicit consent to the transfer, which you can refuse or withdraw at any time in your absolute discretion.
7. Data security
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.
We implement procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to your Personal Data) including notifying you and/or the relevant data protection regulator where we are legally required to do so.
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 instruction and they are subject to a duty of confidentiality.
8. Data retention
How long will you use my Personal Data for?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or your organisation.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax purposes.
Details of retention periods for different aspects of your Personal Data are available and if you would like more information, please contact us.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data:
- Request access to your Personal Data.
- Request correction of your Personal Data.
- Request erasure of your Personal Data.
- Object to processing of your Personal Data.
- Request restriction of processing your Personal Data.
- Request transfer of your Personal Data.
- Right to withdraw consent.
- Request the removal from marketing lists.
If you wish to exercise any of the rights set out above, please contact us by email at dataprotection@personcentredsoftware.com
Fees
You will not usually 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
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 facilitate our response.
Time limit to respond
We endeavour to respond to all legitimate requests within one month. Occasionally it could 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.
10. Glossary
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 other lawful basis for the processing). 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 obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Service providers who provide IT and system administration services and other business services to us.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to us.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom
- Analytics and search engine providers who assist us in the improvement and optimisation of our website.
- Subcontractors, partners, agents and other persons who need access to and will use your data in the course of providing services to you or your organisation and for the purposes we specify.
YOUR LEGAL RIGHTS
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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.
- Request the removal at any time from marketing lists or change your marketing preferences.