Privacy Policy
Effective Date: 19 September 2024Last Reviewed: 14 May 2025
This privacy notice tells you what to expect with your personal information.
Contact Details
Introduction
What Information We Collect, Use, and Why
Lawful Bases for Processing Your Data
Where We Get Personal Information From
Who We Share Information With
Data Retention
International Data Transfers
Data Security
Your Data Protection Rights
Complaints
Policy Updates
Contact details
Telephone
020 7164 6057
Introduction
Puraffinity, registered as a company in England and Wales with the registration number 09616956, and with the Information Commissioner’s Office as a controller with the number ZB341074, is committed to protecting your privacy and handling your personal information transparently and securely. This Privacy Policy explains what information we collect, how we use it, your rights, and how you can contact us.
What Information We Collect, Use, and Why
We collect and use the following personal information to provide our services, manage accounts, comply with legal obligations, and improve your experience:
To Provide Services and Goods (including delivery)
Names and contact details
Addresses
Date of birth
Purchase or account history
Payment details (including card or bank information for transfers and direct debits)
Credit reference information
Information relating to compliments or complaints
For the Operation of Customer Accounts and Guarantees
Names and contact details
Addresses
Payment details (including card or bank information for transfers and direct debits)
Purchase history
Account information, including registration details
To Prevent, Detect, Investigate, or Prosecute Crimes
Names and contact information
Customer or client accounts and records
Financial transaction information
For Service Updates or Marketing Purposes
Names and contact details
Addresses
Marketing preferences
Location data
Purchase or viewing history
IP addresses
Website and app user journey information
Records of consent, where appropriate
For Research or Archiving Purposes
Names and contact details
Addresses
Location data
IP addresses
Website and app user journey information
Records of consent, where appropriate
To Comply with Legal Requirements
Name
Contact information
Identification documents
Financial transaction information
Criminal offence data (including Disclosure Barring Service (DBS), Access NI, or Disclosure Scotland checks)
Health and safety information
For Recruitment Purposes
Contact details (e.g., name, address, telephone number, or personal email address)
Date of birth
National Insurance number
Copies of passports or other photo ID
Employment history (e.g., job application, employment references, or secondary employment)
Education history (e.g., qualifications)
Right to work information
Details of any criminal convictions (e.g., DBS, Access NI, or Disclosure Scotland checks)
Security clearance details (e.g., basic checks and higher security clearance)
For Dealing with Queries, Complaints, or Claims
Names and contact details
Address
Payment details
Account information
Purchase or service history
Our Lawful Bases for Processing Your Data
For Providing Services and Goods
Contract: We need to process your information to enter into or carry out a contract with you.
Legitimate Interests: Processing benefits you, our organisation, or others without causing undue risk.
Our legitimate interests include providing services such as collecting customer information to deliver requested services.
For Customer Accounts and Guarantees
Contract: As described above.
Legitimate Interests: Including account management, processing payments, updating customer information, and managing account access.
For Crime Prevention, Detection, Investigation, or Prosecution
Legal Obligation: We are required to process your information in accordance with the law.
For Service Updates or Marketing
Consent: As described above.
For Research or Archiving
Consent: As described above.
For Legal Requirements
Legal Obligation: As described above.
For Recruitment
Contract: As described above.
For Queries, Complaints, or Claims
Consent: As described above.
Where We Get Personal Information From
Directly from you
Health care providers
Publicly available sources
Market research organisations
Suppliers and service providers
Who We Share Information With
Our Data Processors
HR Services Providers: Process candidate recruitment data, employee performance data, payroll data, training data, and offboarding.
Sales and Marketing Services: Process data for sales and marketing emails, analytical research, account information tracking, website lead capturing, and responding to queries.
Others We Share Personal Information With
Professional or legal advisors
External auditors or inspectors
Organisations we're legally obliged to share personal information with
Publicly on our website, social media, or other marketing and information media
Suppliers and service providers
How Long We Keep Information
We keep your personal information for as long as it is required for the purposes that it was collected. For further information on how long we keep your personal information, please contact our Data Protection Officer via email dpo@puraffinity.com
International Data Transfers
If we transfer your personal information outside the UK or EEA, we ensure appropriate safeguards are in place, such as an International Data Transfer Agreement (IDTA), Standard Contractual Clauses (SCCs) or an adequacy decision, to protect your data. When we rely on an IDTA or SCCs, then we will conduct a Transfer Risk Assessment in accordance with the ICO’s guidelines.
Data Security
We implement appropriate technical and organisational measures to protect your personal information, including encryption, access controls, regular security reviews, and staff training.
Your Data Protection Rights
You have the following rights regarding your personal data:
Access: Request a copy of your personal data.
Rectification: Correct inaccurate or incomplete data.
Erasure: Request deletion of your data in certain circumstances.
Restriction: Request restriction of processing.
Objection: Object to processing based on legitimate interests or direct marketing.
Portability: Request transfer of your data to another provider.
Withdraw Consent: Withdraw your consent at any time (where processing is based on consent).
Note that certain rights may not apply depending on the lawful basis for processing.
How to Complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the Information Commissioner's Office (ICO) at the address below.
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Fax: 01625 524510
Updates to This Policy
We may update this policy from time to time. We will notify you of significant changes via our website or by email where appropriate. The date of the latest update is shown at the top of this policy.
For any questions or to exercise your rights, please contact us at dpo@puraffinity.com