Privacy

Important information and who we are

This privacy notice provides information on how we collect and processes your personal data through your use of this website, by phone, email or otherwise including any data you may provide when you enquire about or use our services and/or products. Personal data is information about your from which you can be identified. It does not include anonymous data.


JT Hughes (Oswestry) Limited (Company number 01198620 is the controller and responsible for your personal data (collectively referred to as "the Company", "we", "us" or "our" in this privacy notice).


If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact:

Name or title (Privacy Manager}) Wendy Hughes

Email address: wendy.hughes@jthughes.co.uk

Address: 3 Battlefield Road, Shrewsbury SY1 4AB

If you wish to make a complaint at any time please contact the Information Commissioner's Office (ICO) (www.ico.org.uk).

Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. We do not control these websites and are not responsible for their privacy statements.

 

1. The data we collect about you

a) Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth gender and photographic/video images.

b) Contact Data includes billing address, delivery address, email address and telephone numbers.

c) Financial Data includes financial details, bank account and payment card details.

d) Transaction Data includes details about payments to and from you and other details of purchases and feedback.

e) Recruitment Data includes processing of applications for employment.

f) 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.

g) Profile Data includes purchases of our services and/or products made by you, your interests, preferences, feedback and survey responses.

h) Usage Data includes information about how you use our website, services and or products

i) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.


We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
If you fail to provide 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 services and/or products.

 

2. How is your personal data collected?

  • Direct interactions. You may provide information face to face, or by filling in forms etc. 
  • Automated technologies or interactions. Interacting with our website may allow us to 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 
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below 
    • Technical Data from the following parties:
      • (a) analytics providers such as Google based outside the EU; 
      • (b) advertising networks based inside the EU]; and
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU.
  • Recruitment Data from recruitment agents or response to job advertisements.

 

3. How we use your personal data

a) To perform the contract we are about to enter into or have entered into with you.
b) 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.
c) To comply with a legal or regulatory.


Generally we do not rely on consent as a legal basis for processing personal data other than in relation to 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.

 

4. Purposes for which we will use your personal data

Below are the ways we may use your personal data, which of the legal bases we rely on, and our legitimate interests 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 THE DATA WE COLLECT
(see section 2 above)
HOW WE WILL USE YOUR PERSONAL DATA
(see section 4 above)
To respond to enquiries about our services and products a, b and c a and b (to grow our business)
To process and deliver our services and/or products e.g. managing our relationship with you, billing and collecting money owed to us. a, b, c, d and e a, b  (e.g. to recover monies due to us) and c
To manage our relationship with you including notifying you about changes to our terms and conditions or asking you for feedback on our services and/or products a, b, c and d a, b and c (e.g. to keep our records updated, to improve the quality of our services and to study how customers use our services (and/ or products)
To process and respond to complaints about our services and/or products a, b, c and d a, b and c
To use photographs and/or video images to promote our services and/or products for marketing and promotions a a and b
To enable us to communicate with you about our services and/or products including promotions and newsletters in line with your preferences a, b, c, d and e a, b (e.g. to study how clients use our services, to develop them and grow our business) and c
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) a, b and c b (e.g. for running our business) and c
To secure our offices by using CCTV Identity b
To deliver relevant website content [and advertisements] to you and measure or understand the effectiveness of any such content a, b, c, d, e and f b (e.g. to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences a and b b (e.g. to define types of customers for our services and/or products 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 services and/or products that may be of interest to you a, b, c, d and e b (e.g. to develop our services and grow our business)
To carry out the administration of our human resources to include assessing the suitability, eligibility and fitness to work a, b, c and d b (e.g. to verify your identity and right to work in the United Kingdom)

 

We have established the following personal data control mechanisms in relation to marketing:


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 services (and or products) 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 services and/or products from us and have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any business or company outside the Company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time 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 apply to personal data provided to us as a result of a service or product purchase, customer experience or service or product we provide for you.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used to analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

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. For more information 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. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties 
  • 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. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

 

6. International transfers

If we need to transfer your personal data out of the European Economic Area (EEA), we take all reasonable steps to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • 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. 
  • 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 information regarding data transfers please contact us on the number above.

 

7. Data security

We have put in place appropriate security measures to protect your personal data. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know and appropriate safeguards are in place.

We have 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

We will retain your data as long as necessary to fulfil the purposes for which we collected it. We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, and the purposes for which we process your personal data when deciding on retention periods.

 

9. Your legal rights

You have rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

See Glossary for more information.

If you wish to exercise any of the rights set out above, please contact us.
As a security measure we may ask for 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). 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

We will try to respond to all legitimate requests within one month. 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.

 


10. GLOSSARY

LAWFUL BASIS

Legitimate Interest - the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract - processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation - processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent - a freely given, specific and informed indication of your wishes by which you signify your agreement to personal data relating to you being processed.

THIRD PARTIES

External Third Parties – service providers acting as processors based in the UK such as car manufacturers, finance and warranty providers, lawyers, agents, accountants, insurers, HM Revenue & Customs and other regulatory authorities.

YOUR LEGAL RIGHTS

You have the right to:

Request access - enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction - 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 - 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 local law. 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 - 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.

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.

 

 

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Company information:
JT Hughes(Oswestry) Ltd, 5 Battlefield Road, Shrewsbury, SY14AB. Company Registration Number is 1198620 registered to JT Hughes(Oswestry) Ltd
JT Hughes(Oswestry) Ltd which is authorised and regulated by the Financial Conduct Authority for insurance mediation activities only. All calls may be recorded for training, monitoring and quality purposes.
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Who regulates us?
J. T. Hughes (Oswestry) Ltd, 5 Battlefield Road, Shrewsbury, SY14AB. Our FCA number is 306434.
J. T. Hughes (Oswestry) Ltd's permitted business is arranging general insurance contracts
You can check this on the FCA's register by visiting the FSA's website or by contacting the FSA on 0800 111 6768.
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