Independent Life is committed to respecting and protecting our users’ privacy. This policy applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of such personal data.

Independent Life website sign up captures personal data entered through our website. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

How do we collect data?

We obtain personal data from you when you sign up to receive our regular email newsletters. You can unsubscribe at any time.

What data do we collect?

The types of data collected may include:

• your name
• postal address
• e-mail address
• telephone number

We will only collect personal data to the extent that it is required for the specific purpose notified to you or for the purpose that is clearly apparent from the circumstances in which you provide your data.

How do we use this data?

Data processing will only take place where we are permitted to do so by the relevant data protection or privacy legislation or where you have given your consent to the processing.

We may use your personal data for the following purposes:

• to provide you with the services, products or information you have requested
• to contact you about our future events and services where you have agreed that we may do so (as applicable)
• to manage our events
• to contact you about special events/initiatives where you have agreed that we may do so (as applicable)
• to plan future activities
• to carry out internal administration and housekeeping activities including training our staff
• to maintain and improve our website and IT systems
• for other purposes that are compatible with the above uses provided that your rights are appropriately protected.

Retention of your personal information

We will retain your personal information only for as long as we need it to provide you with the goods, services or information you have requested; to administer your relationship with us; to manage the preferences of our customers; or to comply with the law.

When we no longer need to retain this information, we will always dispose of it securely, using specialist companies if necessary to do this work for us which we review regularly. The below summarises how long we will retain the personal information of the different customers that we engage with:

Subscribers & Event attendees

If you attend our events we will continue to hold your data, so that we can communicate with you as long as there is evidence that you are continuing to have active engagements with us. If you notify us that you wish to have no further contact with us, we will remove your details within 28 days.

Job applicants – if you have applied for employment with us, we will retain the personal data you provide as part of the application process, along with the CV and application form documents you submit, for a period of 12 months from the point at which you last access your application. Lawful basis for processing.

When we process your data, we have to have a lawful basis to do so. The lawful basis of our processing varies depending on the use we are making of your data, but typical examples include:

• Consent – where we ask if we can use your data in a certain way, and you agree to this e.g. to send you certain marketing materials
• Contract – where the processing is required in order to enter into or perform a contract e.g. you buy a product or service from us
• Legal obligation – where we need to use your data to comply with a legal or regulatory obligation.
• Vital interests – where we need to use your data to protect your or other people’s health or life e.g. if you were unfortunate enough to suffer an injury or need medical assistance when attending one of our events
• Legitimate interests – we may use your data if it is reasonably necessary for us (or others) to do so and it is in our/their “legitimate interests” (provided that what the data is used for is fair and does not unduly impact your rights) e.g. carrying out record administration.
• Explicit consent – if you provide us with specific information about your health in order for us to cater for your needs at an event or to send you relevant information about our services we can use it for those purposes
• Vital interests – where we need to use your information to protect your or other people’s health or life e.g. if you were unfortunate enough to suffer an injury or need medical assistance when attending one of our events
• Legal reasons – we may use this type of data if it is necessary to establish, exercise or defence legal claims
• Substantial public interest – we may use this data for safeguarding or insurance purposes, to prevent or detect unlawful activities or dishonesty, for research or statistical use.

Will we disclose the information we collect to third parties?

We may need to share your data with organisations that provide us with data processing services, such as marketing fulfilment businesses, IT service providers, event organisers and payment processing suppliers. We have agreements in place to make sure these organisations only process your data according to our instructions, securely and in line with relevant legislation.

We may share your data with other specified organisations, where you have specifically agreed that we may do so, in order for those organisations to tell you about their activities. We will not share your data if you have not agreed that we may do so.

If we run a joint event with other organisations, we will share necessary information with those other organisations in order to run that event. If the other organisations would like to use your information for other purposes this will be made clear to you and you will be given the opportunity to agree to this.

We may also disclose your data if we are permitted or required to do so by law, where we are enforcing our legal rights or where we merge with another entity.

Direct marketing – we only use your personal data for direct marketing purposes if we are allowed to do this by law or if we have your consent. If we already have an accurate record of your marketing preferences that complies with applicable legislation, we will assume that you are happy to continue to receive marketing information from us in line with those preferences if you do not indicate otherwise when we contact you or you contact us.

However, you can change your direct marketing preferences at any time by contacting us using the details above or via any other unsubscribe mechanism we offer from time to time.

How do we protect personal data?

We also take appropriate measures to ensure that the data disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. We will take all reasonable steps to destroy or suppress, or erase from our systems, all data which is no longer required. We may also contact you from time to time in order to ensure that our records are correct and up-to-date including your marketing preferences.

Your rights You have the right to ask for a copy of the data we hold about you (for which we may charge any relevant statutory fee) and to have any inaccuracies in your data corrected. You also have the right to ask us to stop using your data for direct marketing purposes or prevent processing that is likely to cause you damage or distress or that you believe is no longer in our legitimate interests.

This can include asking us to restrict the processing of your data and/or delete data that we hold about you. If at any stage we process your data with your consent or in connection with a contract and we do this by automated means, you can ask us to provide you with a copy of your data in a structured, commonly used and machine readable format or arrange for this to be transmitted to a third party We shall also comply with any additional rights given to data subjects under new or modified legislation.

Please be aware that your rights do not apply in all circumstances and we may not be obliged to comply with any requests. If you have any queries or complaints about the way we process your personal data or would like to exercise any of your rights, please contact us using the details above.

We may ask you to provide identifying information in order for us to be sure who you are and that you are entitled to make the request. Alternatively, you may contact the Information Commissioner’s Office at http://ico.org.uk for advice or to find out more about your rights as an individual.

Changes – we reserve the right to amend this privacy notice from time to time as our internal operations and objectives change or as may be permitted under applicable law. If we do so, we will post notice of the changes on our website and/or advise you of them by email. By continuing to use our website or services after any notification, you will be deemed to have accepted such changes.

Do we use ‘Cookies’?

‘Cookies’ are small pieces of information stored on the hard drive of a user’s computer which contain information about the user. Independent Life may store information about your user preferences (e.g. preferred text size) using cookies (files which are sent by us to your computer or other access device) which we can access when you visit our site in future. We do this to help enhance your interaction with our web site. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. If you want to prevent our cookies being stored on your computer in future, you may do so by referring to your internet browser’s instructions. You can do this by clicking on the “Help” menu.

Please note, however, that if you disable our cookies you may not be able to access certain areas of our site. Further information on deleting or controlling cookies is available at: www.aboutcookies.org.

We respect your wishes If your personal details change and you want to continue to hear from us, please help us to keep your data up to date by notifying us using the details above. If for any reason you wish to advise us that you no longer require our services or do not want us to contact you or do not want us to share your data with specified third parties for marketing purposes, please let us know by contacting us using the details above.

The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice.

The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. Please do not supply any other person’s personal data to us, unless we prompt you to do so. If you do share your friends’ details with us, please ensure you have their authorisation.