Privacy Policy
1. What this Privacy Policy covers
This is the Privacy Policy for The Hedge website, our related apps, the tools on our website and our social media content (the "Site").
The Hedge (referred to in this policy as "we", "us" or "our") is the "controller" under data protection laws. Where we're processing your personal information in relation to our content and/or Site, we're controller of your personal information.
The main purposes we collect and process your personal information are: to show you relevant content and to improve your experience on the Site; provide the services you sign up for, with you directly when you've agreed to it, or when the law allows us to do this.
To operate the tools on our Site we may sometimes need to share your personal information with other businesses. They'll be responsible for how they process your personal information.
Our Site contains external links to other websites that aren't subject to this Privacy Policy. Please do read our Terms for further information on external links, as well as the terms and conditions and privacy policy of any website you give your personal information to, as you'll be bound by them. We're not liable for anything that happens if you use them.
2. Personal information we collect
The information we collect will depend on how you're using our Site and should usually be clear to you at the time we collect it. If you're using one of our tools we may, depending on the tool, need to get a range of information, such as your name, marital status, benefit entitlements, income and bank account details. We may also use cookies and other tracking technology to collect information about your online browsing behaviour and any devices you've used to access our Site.
3. How we collect and use your personal information
We collect and use your personal information to allow you to interact with the Site. This includes, without limitation, the following:
3.1. The Hedge email newsletter
When you register to receive The Hedge email newsletter we'll use your email address to send you email.
3.2. Product application forms
When you request certain products via application forms on our Site we'll use your personal information so that we can manage your request. If we need to pass your personal information to someone else to meet your request, we'll make it clear at the time you give us your personal information.
3.3. Internal reporting, insight and analysis
We may use your personal information to generate aggregated, anonymised data for the purposes of internal reporting, insight and analysis, enabling us to improve and personalise our Site, the products we offer and search results for our Site. As part of this we also use Google Analytics. See our Cookie Policy for further information. Where necessary this exercise may be carried out on our behalf by someone else – please see section 7 below.
3.4. Site personalisation
We may use your personal information to personalise aspects of our Site, enable your details to be moved across our tools to speed up form filling and for market research. As part of this, we may match your personal information against information that has been collected by someone else. We are always working to make a better Site for you and using your personal information in this way helps us to do this. It also means that if you've given us permission, any communication we send to you is appropriate for your needs.
3.5. Contacting you
We may use your personal information to:
3.5.1. Respond to any communications that you've directed at us;
3.5.2. Invite you to take part in polls and other market research activities carried out by us and on our behalf. Any feedback you provide will only be used to improve our Site and will not be published. It is up to you whether you want to take part in these activities; or
3.5.3. Award you a prize if you've won a competition we're running
If you're providing us with another person's personal information you should first ask them to read this Privacy Policy and our Terms. By giving us personal information about another person you are confirming that they have given you permission to provide the personal information to us and that they understand how their personal information will be used.
4. Why do we process your personal information?
We'll only collect and use your personal information (as described in sections 2 and 3) in accordance with data protection laws. Our grounds for processing your personal information are:
Performance of a contract – To provide you with the services you sign up to.
Consent – We'll only collect and process your personal information where necessary and if you've consented for us to do so.
Legitimate Interests – We may use and process some of your personal information where we've sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of "legitimate interests" as a justification for processing your personal information. Our legitimate interests for processing your personal information are:
To improve our Site. We may use your personal information to undertake demographic segmentation and generate profiling information to help us understand what you might be interested in and for market research. We are always working to make a better Site for you and using your personal information in this way helps us to do this
You have a right to object to our use of your personal information for these legitimate interests, including a right to object to profiling by us (see section 8 below).
5. Use of children's personal information
We don't knowingly collect or store any personal information about children under the age of 16. If you are aged under 16 please get your parent or guardian's permission before you provide any personal information to us.
6. Sharing your personal information with others
We may share your personal information with:
6.1. Our technical partners – For the purposes described above, and for the purposes of providing certain services and enabling your interaction with the Site.
Our technical partners will not be allowed to use your personal information for their own marketing purposes unless you've given permission to receive marketing from them.
6.2. If required or permitted to do so by law;
6.3. If required to do so by any court, the Financial Conduct Authority or any other applicable regulatory, compliance, governmental or law enforcement agency;
6.4. If necessary in connection with legal proceedings or potential legal proceedings;
6.5. If ownership of all or part of our Site is transferred, in which case any purchaser would only be entitled to use that information in a way consistent with this Privacy Policy; and
6.6. In line with our own Terms, which incorporate our Forum Rules (in particular regarding reporting offending Forum users to their ISP or to the authorities if their actions appear to amount to a crime).
7. How you can change permissions
All emails or other forms of communication directly from us to you will include clear instructions on how to unsubscribe.
8. Your information rights and responsibilities
8.1. You have certain rights in relation to the personal information we hold on you:
8.1.1. Right to access – The right to a copy of the personal information we hold about you. We'll ask you to describe the information you require, as well as letting us know about any other email addresses you've used on our Site, to enable us to trace your personal information. Depending on the nature of your request, we may also ask you for your full name, your date of birth and your full address and documents to allow us to verify your identity. Requests for copies of your personal information will be dealt with within one month, unless your request is complicated or if you've made a large number of requests. In these circumstances it may take us longer to deal with your request, in which case we'll let you know;
8.1.2. Right to correct – The right to have your personal information corrected if it is inaccurate or incomplete. Requests for us to correct your personal information will be dealt with within one month, unless your request is complicated or if you've made a large number of requests. In these circumstances it may take us longer to deal with your request, in which case we'll let you know. If we believe that your personal information is accurate, we'll let you know that we won't be amending your personal information and why;
8.1.3. Right to erasure and to restrict our use of your information – The right to request that we delete or remove your personal information from our systems. Data protection laws give exceptions to this right which, if applicable, we'll explain in our response to you;
8.1.4. Right to restrict our use of your information – In some circumstances you can 'block' us from using your personal information or limit the way in which we can use it;
8.1.5. Right to data portability – The right to request that we move, copy or transfer your personal information;
8.1.6. Right to object – The right to object to our use of your personal information including where we use it for our legitimate interests, or where we use your personal information to carry out profiling to inform our market research and user demographics. If you raise an objection we'll stop processing your personal information unless very exceptional circumstances apply, in which case we'll let you know why we're continuing to process your personal information.
8.1.7. Withdrawal of consent – Where you've provided us with consent to use your personal information, you can withdraw this at any time.
We'll use reasonable efforts consistent with our legal duty to provide you with your rights in accordance with data protection laws.
8.2. To make enquiries, exercise any of your rights set out in this Privacy Policy and/or make a complaint please contact us via the contact form on our website.
8.3. If you're not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator. In the UK, this is the Information Commissioner's Office.
9. Cookies
9.1. We use cookies, web beacons, pixel tags and tracking technology to help improve the functionality and performance of our Site.
9.2. The information coming from our use of cookies will be aggregated to provide statistical information about the usage of our Site. However, we don't use any information derived from cookies, nor any IP addresses we collect, to identify any individual user of our Site.
9.3. Some third-party technology we use (eg, embedded videos, social sharing) also drop cookies to improve your experience on their sites.
9.4. For details on what cookies we use, information on how to stop them being stored or how to delete ones already stored, read our Cookie Policy.
10. Where we store your personal information
10.1. Keeping information about you secure is very important to us so we store and process your personal information in accordance with the high standards required under data protection laws. From time to time and for operational reasons the personal information we collect from you may be transferred to and stored in countries outside of the European Economic Area ("EEA"). Your information may also be processed by some of our service providers which operate outside the EEA. Different countries have different data protection and security laws and some of these don't offer the same level of protection as you enjoy under UK data protection laws. However, when we appoint our service providers to help us provide products and services to you (which may include some based in the USA), we take care to ensure that we've put in place contractual protections, for example European Commission-approved contractual clauses, and that our service providers have appropriate security measures in place.
11. How long do we keep your personal information?
Unless a longer retention period is required or permitted by law, we'll only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted. Where you've applied for or purchased products or services via the Site we'll need to keep your personal information for longer for accounting purposes – up to seven (7) years following the date on which it is provided to us. If, having registered for any of our services, you don't use them for a reasonable time (which may vary depending on the service(s) you've registered for) we may contact you to ensure you're still happy to receive communications from us. Even if you delete, or ask us to delete your personal information it may persist on back-up or archival media for legal, tax or regulatory purposes.