Welcome to Freesure and ‘Free Fuel for a Year’ Privacy Notice

Freesure and ‘Free Fuel for a Year’ are promotions offered by The Trade Centre Group PLC (‘TTCG’), which trades as The Trade Centre Wales and The Trade Centre UK. Freesure and ‘Free Fuel for a Year’ are administered for and on behalf of TTCG by TCi Futures Limited (‘TCi’), The Fuel Gift Card is issued by PayrNet Limited (PN) and the Fuel Gift Card is administered by Sodexo Motivation Solutions UK Limited (SMS).

The Trade Centre Group PLC, TCi Futures Limited, PayrNet Limited, and Sodexo Motivation Solutions UK Limited respect your privacy and are committed to protecting your personal data.

This privacy notice will inform you as to how we look after your personal data under Freesure and ‘Free Fuel for a Year’ when you visit our portal. We will also tell you about your privacy rights and how the law protects you.

Important information and who we are:

Purpose of this privacy notice

This privacy notice aims to give you information on how The Trade Centre Group PLC, a company registered in England and Wales (registered number 4921555), collects and processes your personal data through Freesure and ‘Free Fuel for a Year’.

Freesure and ‘Free Fuel for a Year’ are administered for and on behalf of The Trade Centre Group PLC by TCi Futures Limited, a company registered in England and Wales (registered number 13369579), whose registered office is: Pendragon House, Crescent Road, Caerphilly CF83 1XX. The Fuel Gift Card is issued by PayrNet Limited, a company registered in England and Wales (registered number 09883437) whose registered office is: 38 Holborn, London, England, EC1N 2SW and the Fuel Gift Card is administered by Sodexo Motivation Solutions UK Limited (Company No. 02680629) whose registered address is at Avalon House, Breckland, Linford Wood, Milton Keynes MK14 6LD.

The Freesure and ‘Free Fuel for a Year’ portal and services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notices or fair processing notice we may provide you 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.

Data Controller

The Trade Centre Group PLC is the data controller and is responsible for your personal data referred to as (“we”, “us”, “our”) in this privacy notice. TCi Futures Limited, PayrNet Limited and Sodexo Motivation Solutions UK Limited are our data processors.

Data Protection Officer

Freesure and ‘Free Fuel for a Year’ are promotions brought to you by The Trade Centre Group PLC  and has an appointed data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Contact

The DPO can be contacted as follows:

• E-mail address: dpo@ttcg.co.uk
• Postal address: Euro Centre, Neath Abbey Business Park, Neath Abbey, SA10 7DR
• Telephone number: (01792 814300)

You have the right, if you wish to do so, 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 keep our privacy notice under regular review. This version was last updated on 28 June 2022.

The accuracy of your information is important to us. Please keep us informed if your personal data changes during your relationship with us. If you change your email address then please let us know by contacting our marketing department on questions@freesure.co.uk or questions@freefuelforayear.co.uk

Third-party links

Our portal 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. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

We will collect personal data, or personal information, which 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 first name, surname, date of birth, address, mobile phone or landline, e-mail address and bank details, Freesure claim details, ‘Free Fuel for a Year’ schedule details, vehicle details, insurance company and policy details.

• Financial Data includes bank account and payment card details.

• 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 portal and platform, and other technology on the devices you use to access this website.

• Profile Data includes your surname, your preferences, feedback and survey responses.

• Usage Data includes information about how you use our portal.

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

We also collect, use and share ‘Aggregated Data’ such as statistical or demographic data. ‘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 the portal or 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.

We do not collect any Special Categories of Personal Data about you (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 criminal convictions and offences.

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 with you (for example, to provide you with goods or 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.

How is your personal data collected?

We use different methods to collect data about you including:

• Direct interactions. You may give us and/or our data processors your Identity Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services.
  • create an account on our portal.
  • subscribe to our services or publications.
  • enter a survey.
  • give us feedback or contact us; or
  • request marketing to be sent to you.

• Automated technologies or interactions. As you interact with our portal, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using server logs and other similar technologies.

• Third parties or publicly available sources. In addition to our data processors, we will receive personal data about you from various third parties as set out below:
  • Technical Data from analytics providers (such as Google); advertising networks; and search information providers.
  • Contact and Financial Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregator.
  • Identity and Contact Data from publicly available sources.

How we use your personal data

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 contact you.
• 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).
• Where we need to comply with a legal or regulatory obligation.
• Where you have provided your consent.

Purposes for which we will use your personal data

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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest.
In the course of helping you, the customer, with your Freesure claim and your ‘Free Fuel for a Year’ schedule.	Identity (name, date of birth).Contact details (e-mail, contact number, address details). Vehicle details (vehicle make, registration, sold date).Financial (account holder name, account number, sort code).Policy (policy start date, policy number, policy amount, policy documents).Claim details (claim ID and status).Insurance company (insurance details).	Performance of a contract with you.   Necessary for our legitimate interests.
Disclosure of your personal details and your Freesure claim  or ‘Free Fuel for a Year’ schedule to The Trade Centre Group (TTCG).	Identity reference.Contact details (e-mail address).Financial (refund amount).Claim details (policy start date, policy number).	Consent.   Necessary for our legitimate interests.
To register you as a new customer. To send you an initial communication via e-mail to invite you to register and use our sites and services.	Identity (name, date of birth).Contact details (e-mail, contact number, address details).	Performance of a contract with you.   Necessary for our legitimate interests.
To process your Freesure claim or ‘Free Fuel for a Year’ schedule (Manage payment details).	Identity (name, date of birth).Contact details (e-mail, contact number, address details). Vehicle details (vehicle make, registration, sold date).Financial (account holder name, account number, sort code).Policy (policy start date, policy number, policy amount, policy documents).Claim details (claim ID and status).Insurance company (insurance details).Marketing and communications.	Performance of a contract with you.   Necessary for our legitimate interests.
To manage our relationship with you which will include:   Notifying you about changes to our terms or privacy policy.Asking you to leave a review or take a survey.	Identity (name, date of birth).Contact details (e-mail, contact number, address details). Vehicle details (vehicle make, registration, sold date).Financial (account holder name, account number, sort code).Policy (policy start date, policy number, policy amount, policy documents).Claim details (claim ID and status).Insurance company (insurance details).Profile Data.Marketing and communications.	Performance of a contract with you.Necessary to comply with a legal obligation.Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to complete a survey.	Identity (name, date of birth).Contact details (e-mail, contact number, address details). Profile Data.Usage Data.Marketing and communications.	Performance of a contract with you.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 portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Identity (name, date of birth).Contact details (e-mail, contact number, address details).Technical Data (IP address etc).	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).Necessary to comply with a legal obligation.
To deliver relevant portal content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Identity (name, date of birth).Contact details (e-mail, contact number, address details).Profile Data.Technical Data (IP address etc.).Marketing and Communications.	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 portal, products/services, marketing, customer relationships and experiences.	Technical Data (IP address etc.).Usage Data.	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.	Identity (name, date of birth).Contact details (e-mail, contact number, address details).Technical Data (IP address etc.).Usage Data.Marketing and communications.	Necessary for our legitimate interests (to develop our products/services and grow our business).

Note: – 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 grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around Marketing and Advertising.

Third party marketing

For the purposes of marketing, we may share your information with certain third parties, where you have provided your consent.

Opting out

You can ask us or third parties to stop sending you marketing messages or communications at any time by following the links located at the bottom of any marketing related emails we send to you or alternatively, e-mailing questions@freesure.co.uk or questions@freefuelforayear.co.uk

You can request us to stop sending you our communications at any time by:

• Selecting “unsubscribe” at the bottom of each of our communications.

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.

Disclosures of your personal data

We may have to share your personal data with third parties for the purposes set out in the table above.

These include:

• TCi Futures Limited.
• Sodexo Motivation Solutions UK Limited.
• PayrNet limited.
• Third party marketing providers who assist us to provide any services requested from us, included but limited to: email marketing services, SMS marketing service, direct mail and telephone marketing services.
• Third party IT providers who assist us to process your claim.
• 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.
• Organisations who provide services for money laundering checks and other fraud and crime prevention purposes.
• Service providers and agents who provide IT and system administration services.

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. 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.

Organisations who provide services for money laundering checks and other fraud and crime prevention purposes.

Service providers and agents who provide IT and system administration services. Professional advisers including lawyers, auditors and insurers and accounting services. Information Commissioner’s office, HM Revenue & Customs, regulators, law enforcement and other authorities who require reporting of processing activities in certain circumstances.

For further details of the third parties with whom we share your personal data, please contact our marketing department on questions@freesure.co.uk or questions@freefuelforayear.co.uk. Please note that this list is not necessarily exhaustive and may be amended or updated from time to time.

International transfers

Some of our external third parties are based outside the UK and the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK and the EEA. Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the applicable regulatory body.
• Where we use certain service providers, we may use specific contracts approved by the applicable regulatory body which gives personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EEA.

Data security

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 interest and a 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.

The transmission of information via the internet is, unfortunately, not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Data retention

We will not process your personal data for longer than is necessary nor will we process it for purposes beyond what it was collected for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements and our own legitimate interests in retaining your data for a period beyond your policy lifecycle. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including Contact Data, Identity Data, Financial Data and Transaction Data) for six years after they cease being customers, for tax purposes.

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.

We may record calls for training and monitoring purposes, which are retained for a period of 30 days.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include 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 and to check that we are lawfully processing it.

• 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 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 the 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 the 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.

• 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.

• Not to be subject to automated decision making or profiling based on your personal data, including profiling, which has legal or other similarly significant effects on you as a data subject.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer.

No fee is usually required.

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.

We may need to request specific information from you to help us confirm your identity and to 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

We 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 and keep you updated.

Glossary

Legitimate Interest means 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 means 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent means giving people genuine choice and control over how you use their data. If the individual has no real choice, consent is not freely given and it will be invalid. This means people must be able to refuse consent without detriment and must be able to withdraw consent easily at any time.

Statutory Status Disclosure

Freesure

Freesure is a promotion exclusively offered by The Trade Centre Group PLC (‘TTCG’), which trades as The Trade Centre Wales and The Trade Centre UK. TTCG is a company registered in England and Wales (registered number 4921555). Our registered office is Euro Centre, Neath Abbey Business Park, Neath Abbey, SA10 7DR. We are authorised and regulated by the Financial Conduct Authority (registration number 689365) and are permitted to carry on relevant regulated consumer credit activities including acting as a credit broker and not a lender. ‘Freesure is administered for and on behalf of TTCG by TCi Futures Limited, a company registered in England and Wales (registered number 13369579), whose registered office is: Pendragon House, Crescent Road, Caerphilly CF83 1XX.

‘Free Fuel for a Year’

‘Free Fuel for a Year’ is a promotion exclusively offered by The Trade Centre Group PLC (‘TTCG’), which trades as The Trade Centre Wales and The Trade Centre UK. TTCG is a company registered in England and Wales (registered number 4921555). Our registered office is Euro Centre, Neath Abbey Business Park, Neath Abbey, SA10 7DR. We are authorised and regulated by the Financial Conduct Authority (registration number 689365) and are permitted to carry on relevant regulated consumer credit activities including acting as a credit broker and not a lender. ‘Free Fuel for a Year’ is administered for and on behalf of TTCG by TCi Futures Limited, a company registered in England and Wales (registered number 13369579), whose registered office is: Pendragon House, Crescent Road, Caerphilly CF83 1XX. The Fuel Gift Card is issued by PayrNet Ltd. PayrNet Ltd are regulated and authorised by the Financial Conduct Authority (FCA) under firm registration number (FRN) of 900594, to conduct electronic money service activities under the Electronic Money Regulations 2011. The Fuel Gift Card is administered by Sodexo Motivation Solutions UK Limited (Company No. 02680629) whose registered address is at Avalon House, Breckland, Linford Wood, Milton Keynes MK14 6LD.