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 obligation.
Refer to Lawful Basis to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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 data
We have set out below, 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. 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 below.
Purpose/Activity: To register you as a new user:
Type of data: (a) Identity; (b) Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you
Purpose/Activity: To provide the Services to you including:
(a) Allowing you to participate in interactive features of the Services
(b) Providing email integration services
Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications; (f) Third Party User Data
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you(b) Necessary for our legitimate interests
Purpose/Activity: To manage our relationship with you which will include:
(b) Notifying you about changes to our Services.
(c) Asking you to leave a review or take a survey
Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (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)
Purpose/Activity: To administer and protect our business and Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity; (b) Contact; (c) Technical
Lawful basis for processing including basis of legitimate interest: (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 re structuring exercise); (b) Necessary to comply with a legal obligation
Purpose/Activity: To deliver relevant Site content to you in the most effective manner for you and your computer
Type of data: (a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical
Lawful basis for processing including basis of legitimate interest: 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)
Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data: (a) Technical; (b) Usage
Lawful basis for processing including basis of legitimate interest: 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)
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data: (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile; (f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)
Purpose/Activity: To comply with our legal obligations including the prevention of financial crime.
Type of data: (a) Identity; (b) Contact; (c) Transaction; (d) Third Party User Data
Lawful basis for processing including basis of legitimate interest: To comply with a legal obligation
Additional restrictions on the use of third party user data
Use: We will only use access to read, write, modify, or control email message bodies (including attachments), metadata, headers, and settings (Third Party User Data) to provide a web email client that allows users to compose, send, read, and process emails.
Transfer: We will not transfer Third Party User Data to any third party unless doing so is:
- necessary to provide and improve email integration features,
- to comply with applicable laws, or
- as part of a merger, acquisition, or sale of our assets.
Advertising: We will not use Third Party User Data for marketing or advertising purposes and we will not share Third Party User Data with any third party for marketing or advertising purposes.
Human Interaction: We will not allow humans to read Third Party User Data unless:
- we have your specific prior consent to humans reading specific messages (for example for tech support),
- doing so is necessary for security purposes such as investigating abuse,
- to comply with applicable laws, or
- for our internal operations and even then only when the Third Party User Data have been aggregated and anonymised.
Further to the above, we will adhere to Google’s Limited Use Requirements for any information received from Gmail APIs.
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 and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not prevent us using your personal data to contact you other than for marketing purposes (e.g. where we need to contact you in connection with your use of the Services).
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.