Version 1.0 (01.02.2020)
Welcome to the Mr Financial website.
This site is one of many consumer facing websites within the Mr Company and is a trading style of We Breathe Media Limited (website). We are a limited company registered in England under the company number 11179160 and are registered with the Information Commissioner under the WBM entry number ZA451907.
The Mr Company websites help connect our clients with customers like you who may be interested in the products and services they offer. We do this by asking people to give us their permission to share their information with these brands; we also ask affiliated partners to help us identify potential customers, and these partners send emails on our behalf. You can discover more about how we do this in the how we use your information section below.
This privacy policy, along with our cookie policy will explain, as honestly and clearly as we can, why we need your information, how we will use it, with whom we will share it and how we will keep it safe.
Quick links
Who we are
The Mr Company brands operate a range of websites targeted to users with specific interests, for example, Mr Insurer, Mr Financial and Mr Automotive, you can see a full list of our sites here. The Mr Group Brand as explained above is a trading style of ‘We Breathe Media Limited’, and so in this policy when we refer to the ‘Mr’ brand ‘us’ or ‘we’ we mean We Breathe Media Limited.
In order to help get the message of our products out to market, and to signpost old and prospective clients to our sites we operate an Affiliate Network, this is simply an arrangement we have with third party companies to promote our services.
Regardless of whether you have subscribed via this specific website, through one of our other ‘Mr’ Group websites or via an affiliate partner, we will process your information safely here centrally at WBM and predominately in the UK and EEA; although in some specific cases we may process your information in non-EEA countries like the USA, but only with companies which guarantee adequate protection of your information.
Our promise
We will only process and share your personal information where you give us, or one of our partners your permission, or the law allows us to do so.
Our mission is to connect you with our existing and new clients and to do that we need to hold and share your information, but we promise only to do this where you have given us your permission, or you have agreed to our partners contacting you on behalf of our clients. At any time, you can ask us to stop contacting you, and, as long as there are no legal reason why we cannot, we will be happy to suppress your information so that you no longer hear from us.
WBM is the Data Controller for the information obtained under the ‘Mr’ Group brand, in other words, WBM decide and dictate how and why your information will be used. We promise to follow all current data protection, direct marketing and electronic marketing legislation for the territory in which we are operating.
Where we act as what is called a data processor, for example, if working for one of our clients, we shall only process your information according to their lawful instructions.
The services we offer
We may collect and process your personal data for different reasons, simply click on the heading which best suits your relationship with us and find out how and why we need your information
The two main reasons we process your information is with your consent or using what is called legitimate interests. This simply means that we are allowed to process your personal details for offline direct marketing purposes as long as our activities do not override your fundamental rights and freedoms.
In order to offer our service, we work with a range of clients and partners, full details can be found here hyperlink.
Helping clients identify new customers.
This is referred to within the marketing industry as ‘customer acquisition’ or ‘lead generation’, we are usually helping household brands identify new customers for their products and services.
What we collect:
The information which is collected will depend on the exact service offered by our clients but will always entail capturing your contact details (name, email address, address and phone number), IP address, device used (tablet, iPhone, Windows 10 PC) and other information relevant to that campaign. In certain circumstances your location may be inferred by your IP address.
For example, if the product were only targeted at certain age groups, say it was only available to people 50 years of age and older, we may ask for your age or date of birth. Another example may be that we ask to use your specific location to ensure you are located in a specific country, territory or even GPS coordinates so we to advise you of services in your locality – this will better enhance the service which you receive.
To ensure your information is accurate, and before it is sent to the client or added to our systems, we pass it to a number of third party companies to verify your details, for example, your phone number and address. You can see details of these companies here.
It is very rare that we will collect sensitive data, but it may be necessary for specific campaigns, for example, if our client was offering Medical Insurance for higher risk applicants we may need to collect a limited amount of additional medical information, but we would only ever capture this with your permission.
How we collect it:
You are in charge of what information we collect. You will either be asked to enter your details on the sign-up page on our website(s), or you will be emailed by one of our partners with whom you have a pre-existing relationship and will be invited to click on a link to a Mr Company website or our client’s website where you will enter your details directly with us or them.
Although we will only share your information with consent, we will keep a record of all transfers in our own analytics system to both comply with our legal obligations and our own legitimate interests. If you click on any of the links within an email sent by us a record of those clicks may be recorded for analytical purposes.
Why we collect it:
Our specific Mr Company websites help users find deals and services of specific interest to them. Our sites are therefore built to assist a client identify new clients who may be interested in their product or service, for example a credit card company may wish to promote their services via our ‘Mr Financial’ website.
We would also like your permission to contact you directly about other ‘Mr Company offers, and you may also be invited to add your name to our mailing list. To help us monitor if the service is effective and how many new customers have been generated, where we are allowed to do so, we also keep a note of which hyperlinks you have clicked in both the emails and websites.
Our lawful reason for processing:
Where WBM, a specific Mr Company brand or our partners wish to keep you informed or up-to-date about their services, or notify you of their new offerings, which may be via email, SMS, post or sometimes telephone, we will process and share your information based upon your consent with us, our client or our partner.
Although where we are just processing your personal data for our own purposes and especially, for purely telephone or postal purposes, we may rely upon our legitimate interests to keep in touch.
If we, or our clients ever ask you for sensitive personal information such as medical information, then we shall ask for your ‘explicit’ consent before capturing this.
Where we store your information:
Clients will store the information you give them directly on their systems, you will need to check with them where that information is kept. If you ask to be added to our newsletter or database, we shall keep your information within the UK. Our tracking software is based in both the UK and Ireland and email broadcasting, audit and backups are held in the USA but only with organisations who are part of the Privacy Shield Scheme.
Third parties:
As we send campaigns on behalf of our clients, they are the Data Controller and will be responsible for how your data is stored and used. Where you give us permission to add your data to our mailing list, we will only further share that with other parties, clients, or send information on their behalf, if you give additional consent.
To ensure that you are a real person we also share your data with third parties to verify some elements of your information, we do this using some automated decision-making processes. You can see details of our clients and tech partners here
Retention:
We will retain your personal or analytical details for 7 years after the last point in which we interacted. Analytical data is fully or partly anonymised whilst being stored.
We will need to keep such limited information that enables us to comply with any requests to be forgotten either directly from you, or from our clients or partners, indefinitely.
Other information – automated decision-making processes
To try and advise you only about those products or services in which you are interested, and during the registration process to ensure that you meet certain criteria, we use several automated processes. For example, we look at which campaigns you have registered to hear about and advise you about similar products, or a particular service may only be applicable to people between a specific age range and we will calculate check your age (if you gave it to us) falls within this range.
Any specific automated decisions will be advised to you in the privacy notice on that particular page, but are also listed under Tech Partners .
Your data held by the Mr Company (We Breathe Media)
The data which we hold on you will be used to both supply newsletters from us to you, and to send emails with relevant information from our clients.
What we collect:
The information we hold will depend on what information you are happy to give us. However, it will always entail capturing your contact details (name, email address, address and phone number), IP address, device used (tablet, iPhone, Windows 10 PC), other information relevant to that campaign, such as age, earnings, date of birth etc. We will maintain a record of your marketing preferences, such as to which Mr Company website you signed up, the consent wording to which you agreed and your direct marketing channel preference, for example, postal, email, SMS and so on.
You can change your mind at anytime by emailing compliance@webreathemedia.com or calling our Compliance Officer on 0207 098 9878.
To ensure the information we hold is accurate, before it is added to our system we pass it to a number of third-party companies to verify your phone number and address.
How we collect it:
The data we hold will come directly from you via our website capture form. To ensure that the information came from you, we shall send an email to the email address provided giving you full details of our service and a link to this privacy policy. We monitor and record which links within our sites and emails you click on.
Why we collect it:
We wish to maintain a list of individuals who have an interest in specific areas or topics so that we can connect our clients with new customers who may be interested in their products or services. We monitor which hyperlinks you click to help us better understand in which products you are interested.
Our lawful reason for processing:
In 9 out of 10 cases we are relying on your explicit consent to process and share your personal information; in these cases, you can withdraw your consent at any time, and as long as there is no legal reason why we need to retain the data we shall delete or suppress your information from our system.
In a small number of cases, and where we are emailing you about our own products or service, we can rely on our own legitimate interests and what is called a soft opt-in. In other words, if you have asked to receive details from one Mr Company website, and we launch a similar Mr Company site, we may send details of the other service to you.
If you ever make an enquiry or complaint to us, or we have ever sold a product or service to you, then we would continue to hold details on that interaction using our contractual or legal obligations.
There may be some occasions when we are either allowed or compelled by the law to process and store your information, for example to prevent or detect crime, or to comply with our legal obligations under your Right to be Forgotten.
Where we store your information:
Your data will be managed in secure servers based here in the UK or EEA. We also use a combination of email broadcast services, which depending on the campaign, may be based outside of the EEA, but we will only use those that can guarantee adequate protection of your information.
Third parties:
We keep you informed about developments using email broadcast companies and to ensure you are a real person we also share your data with third parties to verify some elements of your information. You can see details of our clients and partners here. We may also share your data if required to do so by law.
Retention:
We will retain your personal or analytical details for 7 years after the last point in which we interacted. Analytical data is fully or partly anonymised whilst being stored.
We will need to keep such limited information that enables us to comply with any requests to be forgotten indefinitely.
Other information
In order to try and advise you only about those products or services in which you are interested, and also during the registration process to ensure that you meet certain criteria, we use a number of automated processes. For example, we look at which links you have followed and advise you about similar products, or a particular service may only be applicable to people between a specific age range and we will calculate check your age (if you gave it to us) to ensure that it falls within this range. Any specific automated decisions will be advised to you in the privacy notice on that particular website.
Visitors to our website
What we collect:
When you visit our website some cookies are essential for our site to run, others are not strictly necessary but help you have a better experience and help us understand the way our site is being navigated, this in turn helps us optimise the site and deliver a better service to you. We require your consent for these non-essential cookies.
As a website visitor all we capture is your IP address, system type (PC, iPhone, Windows 10 etc) and what pages you visit. This is done via Google Analytics and Clear Reports, which is detailed below and in our Cookie Policy. At any time, you can stop the collection of your anonymous data by Google. In certain circumstances your location may be inferred by your IP address.
If you, sign up for a service with us or our clients, at that point we shall capture your name, contact and details as outlined in the ‘Your data held by Mr Company section above. At this point your identity will be known along with the pages you have visited.
How we collect it:
Data is collected by way of cookies placed on your device – you can remove these at any time.
Why we collect it:
As stated above, some cookies are necessary to allow our sites to operate successfully. We use remarketing to remind you of our services in the hope that you will sign up for one of our sites.
Remarketing cookies are managed by third party companies, and they are listed in our partners link below here. The information which they capture is partly anonymous, in that they only have your IP address and pages visited, although in certain circumstances your location may be inferred by your IP address. If at some point you sign up to one of our sites, then only then would your identity be known.
Our lawful reason for processing:
We are relying upon our legitimate interests to use cookies otherwise the site could not run and we capture anonymous or partly anonymous data with your consent to understand how the sites are working and which pages are being viewed.
Where we store your information:
We store details of your activity on our cloud server in the EU. Google Analytics and our remarketing partner are based within the EU.
Third parties:
Information from tracking cookies will be managed by third party companies, more information can be found in our cookie policy. Our website developers, IT support and marketing consultants may also access this part-anonymised data.
Retention:
Anonymised data will be kept indefinitely, other information will be deleted 3 years after the last interaction with the client. We will need to keep such information that enables us to comply with any requests to be forgotten for an indefinite period.
Children
We only target, and knowingly process details of individuals of 18 years of age and older. Unless data is entered accidently or maliciously by a user, client or other third party, we will never deliberately process data of children.
Security
At all times we, and the Processors for which we are responsible, will process your information in line with current UK and EU data protection and electronic marketing legislation. We will put in place sufficient organisational and technical measures to keep your information safe, and where possible store your information in the UK or EEA.
All of our staff are trained in data protection and we also have in place confidentiality agreements to further protect your information. We try, as far as is possible, to ensure that all partners have similar protections in place.
Occasionally we may use a service, such as an email broadcast platform, which is hosted outside of the EEA, but we will take all due care to ensure the safety and security of your information. We shall only use companies outside of the EEA if the EU has deemed them to have adequate data protection measures, or in the case of the USA are part of the Privacy Shield Scheme.
Automated processing
We use a number of automated processes to validate personal details given to us, check certain criteria, for example age or eligibility, and to understand which products are of interest to you.
These automated decisions do not affect your fundamental rights, nor affect you in a legal way but are listed under Tech Partners here
See your rights below for objecting to any processes.
Your rights:
The Data Protection Act and GDPR affords Data Subjects (that is people whose information we capture) certain rights and these are listed below for your convenience: -
- You have the right to access a copy of the personal information we hold about you. You can do this by phone, in writing or by email to the WBM contact details below. We would be happy to help, we will just have to verify your identity before we can proceed.
- You have the right of rectification to amend or update your personal information and ensure we maintain accurate and up to date records and or data about you.
- You have the right to erasure, also known as ‘the right to be forgotten’.
The broad principle underpinning this right is to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing by us or our partners.
To comply with this right, whether the right is activated directly from you or via a client or partner, we shall record limited details in a suppression or do not contact file.
- You have the right to ‘block’ or suppress the processing of your personal data. Processing of your personal information may be restricted in the event it is no longer essential to support the use of services provided to you and/or not part of any contractual, legal or financial requirement to do so.
WBM are permitted to store the personal data, but not further process it. We may retain just enough information about you to ensure that any restriction is respected in future.
- You have the right for data portability which allows individuals to obtain and or reuse their personal data for their own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
- You have the right to object to the processing of your personal information where we are processing this based on your consent, our legitimate interests or the performance of a task in the public interest or exercise of official authority including profiling activity, direct marketing including profiling activity; and processing for purposes of scientific and or historical research and statistics.
- You have right to be made aware of any automated decision-making, that is decisions made on or about you without any human involvement, and/or profiling of your personal information by us.
NB. We use an automated process to validate details given to us, check certain criteria, for example age or eligibility, and to understand which products are of interest to you. These automated decisions do not affect your fundamental rights, nor affect you in a legal way but if you would like to know more, please see the section on automated processing [hyperlink].
- You have an absolute right to ask us to stop sending you direct mail or email.
For some processing you will have given us permission to process your information, and in these cases, you can withdraw your consent at any time. In certain situations, these rights may not apply, for example if you entered into a membership minimum term contract, we may have to write to you about your membership even if you asked us previously not to, but we would not send you direct marketing.
To activate any of your rights contact us on the details below.
Changes to This Privacy Notice
Businesses develop over time, and we reserve the right to update this Privacy Notice at any time, and we will provide you with notice of any significant changes. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose.
We may process your personal data without your knowledge or consent where required to do so by law, or instructed by a UK, or in certain circumstances, EU court.
We will only share your information with those third parties outlined above, or where we are required to do so by law, and if we ever sell the business, or are taken over by another company, whilst your information will be transferred to that company, you will receive due notice of the transfer.
Contact details
If you have any questions or concerns do not hesitate to contact us.
The Compliance Officer
WE BREATHE MEDIA LIMITED
91 Waterloo Road
London, SE1 8RT
T. 0207 098 9878
E. compliance@webreathemedia.com
ICO Registration Number: ZA451907
Companies House Registration number: 11179160 (registered in England)
Information Commissioners Office
If you are unhappy with how we have processed your information, you have the right to lodge a complaint with the Office of the Information Commissioner, contact details below.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Helpline: 0303 123 1113 (local rate) or +44 1625 545 745
