1. Important information and who we are
About this privacy notice
This privacy notice explains how Your Co-op Broadband, Your Co-op Mobile, Your Co-op Business Solutions, Your Co-op Energy and Co-operative Flexible Benefits collects and processes your personal information. We would encourage you to read this information.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Who’s responsible for your personal information?
We refer to Your Co-op Broadband, Your Co-op Mobile, Your Co-op Business Solutions, Your Co-op Energy and Co-operative Flexible Benefits in this statement. These are trading names of The Midcounties Co-operative Limited, which is part of The Midcounties Co-operative Group. The Midcounties Co-operative Limited is responsible for this website and is the ‘data controller’ for your data (collectively referred to as “Your Co-op Broadband, Your Co-op Mobile, Your Co-op Business Solutions, Your Co-op Energy and Co-operative Flexible Benefits”, “we”, “us” or “our” in this privacy notice).
How can you contact us?
We have appointed a data protection manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Manager at
data-protection@midcounties.coop or by writing to: Data Protection Manager, Secretariat Group, The Midcounties Co-operative, Co-operative House, Warwick Technology Park, Warwick CV34 6DA.
You can also contact us using the contact details on our websites.
If you do not think that we have processed your data in accordance with this notice you should let us know as soon as possible. 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.
Changes to the privacy notice and your duty to inform us of changes
We may change this privacy notice from time to time. You should check this notice occasionally to ensure you are aware of the most recent version.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Links to other websites
This website may include links 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. When you leave our website, we encourage you to read the privacy notice of every website you visit as we do not control those.
2. The kind of information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. 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 your name, title, National Insurance number, date of birth, gender and your Midcounties Co-operative Society membership number.
- Contact Data includes your postal address, billing address, site address where we provide services, email address and telephone numbers.
- Sensitive Data includes information concerning medical conditions, disabilities, religious or philosophical beliefs and criminal convictions and offences.
- Financial Data includes bank account and payment card details, as well as information about bankruptcy, insolvency and County Court Judgements.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- 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.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey and promotional responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
When you first order any services from us, or buy certain new services, we run a credit check on you. To do that we pass some of your personal information to credit reference agencies. Further details of how we use credit reference agencies are set out later in this notice.
We, and our suppliers, keep information about how you're using your broadband to help us understand and manage traffic flows on our network, and improve our services. That includes IP addresses and other traffic data including websites you've visited. We are sometimes contacted by third parties who monitor illegal online file sharing on behalf of copyright holders. If we receive a claim that there has been illegal sharing on your broadband service, we may use your IP address to notify you. But unless we are required to by law, we will not disclose your personal information to the copyright holder or any party acting on their behalf.
When you use our telecommunication services, we record certain things about that use. They include the amount you spend, the numbers you call or text (but not the content of the text), the numbers that call or text you, and the location of the cellthat you make a call from. We also record the time and the length of all incoming and outgoing services like calls, texts and picture messages (MMS) and data use while you're in the UK and abroad.
We 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 but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Apart from the Sensitive Data referred to above, we do not collect any other Special Categories of Personal Data about you (this also includes details about your race, sex life, sexual orientation, political opinions, trade union membership and information about your genetic and biometric data).
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 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 our products and services). We will notify you if this is the case at the time.
3. How your personal information is collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial, Sensitive and Transaction Data by filling in forms or by corresponding with us online or by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to purchase our products and services;
- enquire about our goods and services;
- subscribe to our services or publications;
- request marketing to be sent to you;
- enquire about our community involvement;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Profile and Usage Data. We will also collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Credit Reference Agencies. We and our service providers will search your record at credit reference agencies who will supply us with credit information as well as information from the Electoral Register, about you. We may use credit scoring or other automated decision-making systems when assessing your application and to verify your identity. Credit searches and other information which is provided to us and/or the credit reference agencies, about you and those with whom you are linked financially may be used by us and other companies on an ongoing basis to make other credit decisions about you, or other members of your household to support responsible lending. This information may also be used for debt tracing and the prevention of fraud and money laundering as well as the management of your account. Information held about you by the credit reference agencies may already be linked to records relating to one or more of your partners and you may be treated as financially linked, which means your application wil be assessed with reference to any associated records. Prior to such an assessment you will first need to get your partner’s consent before their information is disclosed. More information about Credit Reference Agencies and how they use personal information is available at
www.transunion.co.uk/legal/consumer-centre.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators and affiliate marketing partners.
- Identity and Contact data from your employer (Co-operative Flexible Benefits only)
- Identity and Contact Data from publicly available sources such as social media.
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
4. How we use your personal information
It’s important that you understand what we’ll do with the data that we hold about you.
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.
- 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.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to the collection and use of Sensitive Data and sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal information
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. 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.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To carry out our obligations arising in connection with any contracts entered into between you and us, or between you and a third party supplier, including: - (a) To communicate with you regarding your order
- (b) Manage payments, fees and charges
- (c) Collect and recover money owed to us
- (d) Resolve complaints and deal with disputes
- (e) To comply with our obligations regarding Vulnerable Customers
| - (a) Identity
- (b) Contact
- (c) Sensitive
- (d) Financial
- (e) Transaction
- (f) Marketing and Communications
| - (a) Performance of a contract with you
- (b) Compliance with a legal obligation, including compliance with anti-money laundering legislation relating to foreign currency transactions
- (c) Necessary for our legitimate interests (to recover debts due to us)
- (d) The provision of support services in relation to data relating to your health,
- (e) Consent in relation to the processing of Sensitive Data such as your religious or philosophical beliefs
|
To manage our relationship with you which will include: - (a) Notifying you about changes to our service, terms or privacy policy
- (b) To notify you about any changes to our services such as improvements or scheduled maintenance that may affect our services
- (c) Asking you to leave a review or take a survey
- (d) Recording telephone conversations
- (e) Keeping records of our dealings with you and dealing with queries or complaints
- (f) Collect and recover money owed to us
| - (a) Identity
- (b) Contact
- (c) Profile
- (d) Marketing and Communications
| - (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, to study how customers use our products/services and for colleague training and customer service)
|
| To enable you to subscribe for our newsletter, take part in a prize draw, promotion or competition or complete a survey | - (a) Identity
- (b) Contact
- (c) Profile
- (d) Usage
- (e) Marketing and Communications
| - (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 this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | - (a) Identity
- (b) Contact
- (c) Technical
| - (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)
- (b) Necessary to comply with a legal obligation
|
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | - (a) Identity
- (b) Contact
- (c) Profile
- (d) Usage
- (e) Marketing and Communications
- (f) Technical
| 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 our website, products/services, marketing, customer relationships and experiences | | 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 our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | - (a) Identity
- (b) Contact
- (c) Technical
- (d) Usage
- (e) Profile
- (f) Marketing and Communications
| Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
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 or if you provided us with your details when you entered a competition or registered for a promotion.
Third-party marketing
As a co-operative, we are owned by our members. As such, we may contact our members regarding the range of goods, products and services that are available to them as a member. If you are a member, we may share your personal data with other legal entities within The Midcounties Co-operative Group for the purpose of marketing goods, services and products available to you as a member. We will get your express opt-in consent before we share your personal data with any company outside The Midcounties Co-operative Group for marketing purposes.
For non-members, we will get your express opt-in consent before we share your personal data with any internal or external third parties, such as other legal entities in The Midcounties Co-operative Group, or any company outside The Midcounties Co-operative Group for marketing purposes.
Opting out
We won’t use your personal data for marketing purposes at all if you’ve told us not to. You can ask us (or third parties acting on our behalf) to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, via your online account or by contacting us at any time.
Cookies
For more information about the cookies we use, please see our
cookie policy.
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 wish to get an explanation 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.
5. Sharing your personal information
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal third parties such as other legal entities in The Midcounties Co-operative Group who provide administrative services and undertake management reporting.
- External third parties including the following:
- Government bodies or other organisations who are responsible for regulating the industries in which we operate.
- Third party suppliers who help us to provide services to you.
- Directory Enquiries (for relevant services only) unless you have requested to be ex-directory.
- Our Affinity partners or Agents who introduced you to our services in order to provide them with commission details.
- Organisations to which we may outsource certain of our activities, such as printing, mailing and distribution services.
- Organisations that provide customer identity and address verification services.
- Organisations doing research for us.
- Organisations for the detection, investigation and prevention of crime, such as the National crime Agency in respect of money laundering.
- Financial organisations for purposes such as payment processing, finance plans and refunds.
- 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 notice.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
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.
6. International transfers
Data may be processed by staff operating outside the UK or European Economic Area (EEA) who work for us or for one of our suppliers. For example, such staff may be engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We take steps to ensure that if information is transferred outside of the UK or EEA by our service providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. Transfers are made in accordance with the requirements of the Data Protection Act 2018 and UK General Data Protection Regulations and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
7. Keeping your information secure
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. For example, all information you provide to us is stored on secure servers which means that your information can’t be read by anyone who doesn’t need to see it. Any payment transactions will be encrypted using SSL technology. When you get in touch with us, we’ll ask you a couple of security questions before we share any personal details just to check it’s you. In addition, we limit access to your personal data to those colleagues, 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.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.
We strongly recommend that you do not disclose your online account log in details to anyone. Please always remember to logout of your account when you have finished using it.
We have also 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.
8. Data retention
How long will you use my personal data for?
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.
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
