Privacy Policy

1. Welcome to the When2Call Limited privacy policy.
2. When2Call Limited (company number 12156697) (collectively referred to as “When2Call”, "we", "us" or "our" in this privacy policy), respects your privacy and is committed to protecting your Personal Data. This privacy policy will inform you how we look after your Personal Data when you use our Application and Services (as defined below) and tells you about your privacy rights and how the law in our jurisdiction protects you.

1. Capitalised terms used herein but not otherwise defined shall have the meanings given in our Terms of Service which can be found on the Application.
2. The following capitalised terms shall have the following meanings:

“Anonymous Data” means Personal Data that has been amended to the extent that it no longer contains any identifying information and thus, no longer constitutes Personal Data;

“Children” any person under the age of 16;

“Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed as outlined in the Data Protection Legislation. 

“Data Protection Legislation” all applicable data protection and privacy legislation in force from time to time in the UK including the General Data Protection Regulation ((EU) 2016/679); the Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended.

“Personal Data” has the meaning given to it in the Data Protection Legislation.

“Processor” means any natural or legal person who processes the data on behalf of the Controller. 

1. This privacy policy aims to give you information on how When2Call collects and processes your Personal Data through your use of the web application which can be found at https://when2call.com and any other applications (including without limitation for smart devices) published by us from time to time (the “Application”), and any Personal Data you may provide through the Application when you send a Message or send us your details.
2. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them unless specifically stated.

1. The Application is not intended for Children and we do not knowingly collect data relating to Children. When2Call accepts no liability for the processing of any data relating to Children where When2Call was not aware that the subjects were Children.

1. When2Call is a data Controller in respect of certain Personal Data provided by Users via the Application when they create an Account, and by email.
2. When2Call is a data Processor in respect of any Personal Data processed by When2Call on behalf of any User in the manner dictated by the User and by third parties including suppliers, provided through a variety of methods.

1. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if any aspect of your Personal Data changes during your relationship with us. Any previous data held on you will be deleted to the fullest extent possible.

1. The Application may include links to third-party websites, plug-ins and applications. Clicking on any of these links or enabling those connections may allow third parties not associated with When2Call to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
2. We encourage you to read the privacy policy of every website you visit, but, for the avoidance of doubt, When2Call accepts no liability for any data that has been unlawfully processed by third parties as a result of you accessing these links.

1. We may collect, use, store and transfer different kinds of Personal Data about you, which include but are not limited to, the following categories:

Identity Data: means data that includes your name any other information that may be used within your Message.

Contact Data: means data that includes your contact information, such as: your email address, phone number, and any other information that may be used within your Message.

Account Data: means data that includes Messages sent from you or to you and Contact Data.

Financial Data: means data that includes your financial details, such as your bank account information and payment card details.

Transaction Data: means data that includes details about any payments to and from you relating to When2Call and the details of products and/ or Services you have purchased from us.

Technical Data may include internet protocol (IP) addresses you may have visited, your login data for When2Call, the type and version of browser you are using, the time zone setting and location from which you are accessing the Application, browser plug-in types and versions, which operating system and platform are being used and other technology on the devices you use to access the Application.

Usage Data includes information about how you use the Application and our Services such as the full uniform resource locations (URL) clickstream to, through and from the Application (including date and time), pages you viewed or searched for, page response times, download errors, length of visits of certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Marketing and Communications Data includes your preferences in receiving marketing communications from us and/or our third parties and what are your communication preferences.

2. 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 (which has been collected and processed lawfully) but is not considered to constitute Personal Data under the Data Protection Legislation. This is because the data does not directly or indirectly reveal your identity.
3. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Application feature. This will help us to ensure that we are responding to the preferences of our users and delivering the best possible services. However, if we combine or connect Aggregated Data with your Personal Data in any way so that it can directly or indirectly identify you, the combined data will be considered Personal Data which will only be used in accordance with this privacy policy.
4. We do not collect any “Special Categories of Personal Data” about you. Special categories mean the kinds of data recognised by the Data Protection Legislation as being more sensitive in nature than Personal Data. 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 whether you have any prior criminal convictions and/or offences.

1. Where we need to collect Personal Data by law, or under the terms of a contract we have with you 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 (for example, to provide you with goods or the Services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time of contracting.
2. For the avoidance of doubt, When2Call accepts no liability for any losses arising from their inability to fulfil any contractual requirement as a result of your failure to provide the data required.

1. We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity and Contact information by registering your Account or by corresponding with us by post, phone, email, via our Application or otherwise. This includes Personal Data you provide when you:
• register or update your Account with us; or
• use our Services, including any content or information generated by your Message; or
• request for marketing material to be sent to you; or
• request for more information related to our Services to be sent to you;
• request for our invitation-only programme to be sent to you;
• enter a competition, promotion or survey on the Application; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our Application, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
  • analytics providers;
  • advertising networks; and
  • search information providers.
• Identity and Contact Data from publicly availably sources such as Companies House.

1. We will only use your Personal Data when and to the extent permitted by the Data Protection Legislation. Most commonly, we will use your Personal Data in the following circumstances:
• Where we post on the Application any information that you wish to post as part of using our Services.
• Where to provide to any other User with whom you have sought to share your personal information.
• Where we need to notify you about changes to our Services.
• Where we need to contact you about your account and our Services.
• 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.
2. Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

1. 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 legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
2. 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.
3. For the avoidance of doubt, this table is not exhaustive of the ways in which When2Call may use your Personal Data and there may be occasions where we require additional information.

Purpose/Activity	Type of data	Lawful Basis for Processing Including Basis of Legitimate Interest
To register you as a User	(a) Identity Data (b) Contact Data	Performance of a contract with you
To enable you to send a Message	(a) Identity Data (b) Contact Data (c) Account Data (d) Financial Data	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity Data (b) Contact Data (c) Account Data (d) Marketing and Communications Data	(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, so that we can develop our services to suit the demands and preferences of those using our Application and/or Services)
To provide you with information on our programme or Services that you have indicated are of interest to you, or which we reasonably believe are of interest to you	(a) Identity Data (b) Contact Data (c) Account Data (d) Marketing and Communications Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to provide services to customers)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity Data (b) Contact Data (c) Account Data (d) Usage Data (e) Marketing and Communications Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and the Application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity Data (b) Contact Data (c) Technical Data	(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)
To deliver relevant Application content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity Data (b) Contact Data (c) Account Data (d) Usage Data (e) Marketing and Communications Data (f) Technical Data	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 the Application, products/services, marketing, customer relationships and experiences	(a) Technical Data (b) Usage Data	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Application updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you	(a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Account Data (f) Marketing and Communications Data	Necessary for our legitimate interests (to develop our products/services and grow our business in a way that is compatible with the preferences of those using them)

4. 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.
5. 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.
6. 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.

1. We may use your Identity Data, Contact Data, Account Data, Technical Data, Usage Data and Marketing and Communications Data to form a view on what we think that you may want or need, or what we may be able to provide that would be of interest to you. This is how we decide which products, offers, services and marketing information may be relevant for you.
2. We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. Once you have given consent for us to contact you with this information, you may withdraw any consent given to receive direct marketing communications from us by clicking the opt-out link in any marketing email or by contacting us directly.
3. You may receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, consented to us using your Personal Data to contact you with this information and have not yet exercised your right to opt out of receiving that marketing and promotional information.

1. We will get your express opt-in consent before we share your Personal Data with any other company for marketing purposes.
2. You can ask us or third parties to stop sending you marketing messages or processing your Personal Data at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. In the event that you have not contacted us directly with your updated preferences, we will continue to process your Personal Data until such a time that we are informed directly of your withdrawal of consent.
3. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of you purchasing services from us.

1. Cookies are small pieces of text and data sent to your web browser by a website you visit. A cookie file contains such information as how long was spent on that particular website, the site preferences and how frequently the website is visited. These cookies are stored in your web browser and analysed by us to ensure that your preferences are stored. We also use the data from the cookies to assess which of the content on our Application appears to be more engaging and attractive to you. The data is then applied by us to try and ensure that any subsequent use of our Application is both easier and more engaging for you and your preferences are recognised.
2. Our Application uses cookies to distinguish you from other users of the Application. This helps us to provide you with a good experience when you browse the Application and also allows us to improve the Application.
3. We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of the Application. If you block these cookies, the Application will not operate properly.
• Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors navigate around the Application when they are using it. This helps us to improve the way the Application works, for example, by allowing us to tailor the services to try and ensure that users are finding what they are looking for easily and their preferences are stored for future reference.
• Functionality cookies. These cookies are used to recognise you when you return to the Application. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
4. Please note that External Third Parties may also use cookies, over which we have no control. When2Call accepts no liability in relation to any use of cookies by any third-party,
5. 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 the Application may become inaccessible or not function properly. When2Call accepts no liability for any under-performance of the Application as a result of your refusal or disabling of cookies.

1. We may have to share your Personal Data with the third parties, including but not limited to those parties set out below, for the purposes set out in the table in paragraph 12 above.
• External third parties which include processors in the following categories:
  • Payment providers
  • Analytics providers
  • Advertising partners
  • Customer Service providers
  • Our hosting provider
• 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 policy.
2. We may sell data derived from usage of the Application and views and downloads of pages, profiles and adverts on the Application which will always be in aggregated and anonymised form to customers, purchasers and retailers.
3. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers 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 which, for the avoidance of doubt, will be in accordance with the purposes for which the data was collected.

1. Some of our external third parties are based outside the European Union (EU) so their processing of your Personal Data will involve a transfer of data outside the EEA.
2. Whenever we transfer your Personal Data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
   • Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
   • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
3. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EU.

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. 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 instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

1. 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. Once these have been satisfied, the Personal Data will either be deleted or amended to the extent that it would be considered Anonymous Data.
2. 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.
3. In some circumstances you can ask us to delete your Personal Data: see Erasure Request below for further information. In some circumstances we may 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.

1. Under certain circumstances, you have rights under the Data Protection Legislation in relation to your Personal Data.
2. 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.

   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 the Data Protection Legislation. 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. In addition, this does not provide you with routine access to our systems and processes and only the extraction of your Personal Data.

   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.

3. If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

4. You will not 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

5. 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 speed up our response.

Time limit to respond

6. We try to respond to all legitimate requests within one month of the time we receive all of the information required to complete your request. Occasionally it may 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.

1. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
2. 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 (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.
3. Our details are:

Full name of legal entity: When2Call Limited (company number 12156697)

Postal address: Sg House, 6 St. Cross Road, Winchester, England, SO23 9HX

Email: support@when2call.com