Privacy Policy

BACKGROUND:

32 Squared Protect Ltd understands that your privacy is important to you and that you
care about how your personal data is used and shared online. We respect and value
the privacy of everyone who visits this website, www.ableplan.uk (“Our Site”) and
will only collect and use personal data in ways that are described here, and in a
manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your
acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site.
If you do not accept and agree with this Privacy Policy, you must stop using Our
Site immediately.

1. DEFINITIONS AND INTERPRETATION

In this Policy the following terms shall have the following meanings:

“Cookie”
means a small text file placed on your computer or device by Our Site when you visit
certain parts of Our Site and/or when you use certain features of Our Site. Details
of the Cookies used by Our Site are set out in section 13, below;

“Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive)
Regulations 2003;

“Personal Data”
means any and all data that relates to an identifiable person who can be directly or
indirectly identified from that data. In this case, it means Personal Data that you
give to Us via Our Site. This definition shall, where applicable, incorporate the
definitions provided in the EU Regulation 2016/679 – the General Data Protection
Regulation (“GDPR”); and

“We/Us/Our/the Company”
Means 32 Squared Protect Ltd, Company Number 11947701.
Registered Address: Henleaze Business Centre, 13 Harbury Road, Henleaze, Bristol BS9 4PN

2. INFORMATION ABOUT US

2.1 Our Site is owned and operated by the Company.
2.2 Our Data Protection Officer can be contacted at hello@32squaredprotect.co.uk.
Data is collected, processed and maintained in accordance with the Data
Protection Act 1998. Registration Number: ZB460630

3. WHAT DOES THIS POLICY COVER?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links
to other websites. Please note that We have no control over how your data is
collected, stored, or used by other websites and We advise you to check the privacy
policies of any such websites before providing any data to them.

4. YOUR RIGHTS

4.1 As a data subject, you have the following rights under the GDPR, which this
Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of
personal data;
4.1.2 The right of access to the personal data We hold about you (see
section 12);
4.1.3 The right to rectification if any personal data We hold about
you is inaccurate or incomplete (please contact Us using the
details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete
any personal data We hold about you (We only hold your personal
data for a limited time, as explained in section 6 but if you
would like Us to delete it sooner, please contact Us using the
details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your
personal data;
4.1.6 The right to data portability (obtaining a copy of your personal
data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for
particular purposes; and
4.1.8 Rights with respect to automated decision making and
profiling.
4.2 If you have any cause for complaint about our use of your personal data,
please contact us using the details provided in section 14 and we will do
our best to resolve the problem for you. If we are unable to help, you also
have the right to lodge a complaint with the UK’s supervisory authority, the
Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information
Commissioner’s Office or your local Citizens Advice Bureau.

5. WHAT DATA DO WE COLLECT?

Depending upon your use of Our Site, We may collect some or all of the following
personal and non-personal data (please also see section 13 on our use of Cookies and
similar technologies and Our Cookie Policy):

name;
date of birth;
contact information such as email addresses and telephone numbers;
demographic information such as post code;
IP address;
web browser type and version;
operating system;
a list of URLs starting with a referring site, your activity on Our Site, and the
site you exit to;

6. HOW DO WE USE YOUR DATA?

6.1 All personal data is processed and stored securely, for no longer than is
necessary in light of the reason(s) for which it was first collected. We
will comply with Our obligations and safeguard your rights under GDPR at all
times. For more details on security see section 8, below.
6.2 Our use of your personal data will always have a lawful basis, either
because it is necessary for Our performance of a contract with you, because
you have consented to Our use of your personal data (e.g. by subscribing to
emails), or because it is in Our legitimate interests. Specifically, We may
use your data for the following purposes:

6.2.1 Supplying Our services to you (please note that We require your
personal data in order to enter into a contract with you);
6.2.2 Personalising and tailoring Our services for you;
6.2.3 Replying to emails from you;
6.2.4 Analysing your use of Our Site and gathering feedback to enable
Us to continually improve Our Site and your user experience;
6.2.5 With your permission and/or where permitted by law, we may also
use your data for marketing purposes which may include
contacting you by email or telephone with information, news and
offers on services. We will not, however, send you any
unsolicited marketing or spam and will take all reasonable steps
to ensure that we fully protect your rights and comply with our
obligations under GDPR and the Privacy and Electronic
Communications (EC Directive) Regulations 2003.
6.3 You have the right to withdraw your consent to us using your personal data
at any time, and to request that we delete it.
6.4 We do not keep your personal data for any longer than is necessary in light
of the reason(s) for which it was first collected. Data will therefore be
retained for the following periods (or its retention will be determined on
the following bases):
24 Months from the date of the last submission of data.

7. DO WE SHARE YOUR DATA?

7.1 We will contract a third party to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.2 We may compile statistics about the use of Our Site including data on
traffic, usage patterns, user numbers, sales, and other information. All
such data will be anonymised and will not include any personally identifying
data, or any anonymised data that can be combined with other data and used
to identify you. We may from time to time share such data with third parties
such as prospective investors, affiliates, partners, and advertisers. Data
will only be shared and used within the bounds of the law.
7.3 In certain circumstances, we may be legally required to share certain data
held by us, which may include your personal data, for example, where we are
involved in legal proceedings, where we are complying with legal
requirements, a court order, or a governmental authority.
7.4 You have the right to withdraw your consent to Us using your personal data
at any time, and to request that We delete it.
7.5 We do not keep your personal data for any longer than is necessary in light
of the reason(s) for which it was first collected.

8. HOW AND WHERE DO WE STORE YOUR DATA?

8.1 We only keep your personal data for as long as We need to in order to use it
as described above in section 6, and/or for as long as We have your
permission to keep it.
8.2 Your data will only be stored within the European Economic Area (“the EEA”)
(The EEA consists of all EU member states, plus Norway, Iceland, and
Liechtenstein). Data security is very important to Us, and to protect your
data We have taken suitable measures to safeguard and secure data collected
through Our Site.

9. WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?

9.1 We may, from time to time, expand or reduce Our business and this may
involve the sale and/or the transfer of control of all or part of Our
business. Any personal data that you have provided will, where it is
relevant to any part of Our business that is being transferred, be
transferred along with that part and the new owner or newly controlling
party will, under the terms of this Privacy Policy, be permitted to use that
data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner,
you will be contacted in advance and informed of the changes. When contacted
you will be given the choice to have your data deleted or withheld from the
new owner or controller.

10. HOW CAN YOU CONTROL YOUR DATA?

10.1 In addition to your rights under the GDPR, set out in section 4, when you
submit personal data via Our Site, you may be given options to restrict Our
use of your data. In particular, We aim to give you strong controls on Our
use of your data for direct marketing purposes (including the ability to
opt-out of receiving emails from Us which you may do by unsubscribing using
the links provided in Our emails and at the point of providing your
details).
10.2 You may also wish to sign up to one or more of the preference services
operating in the UK: The Telephone Preference Service (“the TPS”), the
Corporate Telephone Preference Service (“the CTPS”), and the Mailing
Preference Service (“the MPS”). These may help to prevent you receiving
unsolicited marketing. Please note, however, that these services will not
prevent you from receiving marketing communications that you have consented
to receiving.

11. YOUR RIGHT TO WITHHOLD INFORMATION

11.1 You may access Our Site without providing any data at all. However, to use
all features and functions available on Our Site you may be required to
submit or allow for the collection of certain data.
11.2 You may restrict Our use of Cookies. For more information, see section 13.

12. HOW CAN YOU ACCESS YOUR DATA?

You have the right to ask for a copy of any of your personal data held by Us (where
such data is held) Under the GDPR, no fee is payable and We will provide any and all
information in response to your request free of charge. Please contact Us using the
contact details below in section 14.

13. OUR USE OF COOKIES

We use Cookies to help us improve your experience when you browse on Our Site and
also to analyse how you use it, so we can improve it in the future. For detailed
information about Cookies, how we use them and the applicable Cookie Law, please
refer to Our Terms and Conditions which can be found here.

14. CONTACTING US

If you have any questions about Our Site or this Privacy Policy, please contact Us by
email at hello@32squaredprotect.co.uk. Please ensure that your query is clear,
particularly if it is a request for information about the data We hold about you (as
under section 12, above).

15. CHANGES TO OUR PRIVACY POLICY

We may change this privacy policy from time to time (for example, if the law
changes). Any changes will be immediately posted on our site and you will be deemed
to have accepted the terms of the privacy policy on your first use of our site
following the alterations. We recommend that you check this page regularly to keep
up-to-date.

16. COMPLAINTS

Our aim is not to give you cause to complain. However, if you feel you do have cause to complain, you are welcome to submit your concerns to us by email at complaints@32squaredprotect.co.uk. Under the GDPR you have the right to complain to the Information Commissioner’s Office (www.ico.org.uk). We treat any complaints very seriously and we would appreciate the opportunity to try to resolve any issues in the first instance.

17. We work with Contact State

We work with Contact State in order that we can pass on your request to our partners correctly. Contact State provides lead validation services to us and our insurance provider partners and their intermediaries. Contact State receives “de-identified” data from us about your request – this means devoid of any contact information, or anything else identifying you as an individual person in the “real world”. It uses that de-identified data to help confirm your request has been submitted by a “real” human and not a robot, or automated request generator. This is done by examining a “browser fingerprint” associated with your request – it contains, for example, details of the model of device you are using, your Internet browser, and the region from which you submit your request. Contact State retains that de-identified data for its own purposes as “data controller” and uses it to help verify requests submitted through other websites.

If you do not want us to pass your de-identified data to Contact State, please contact us by emailing hello@32squaredprotect.co.uk.

We also use Contact State to check some basic details in your submission (for example, the postcode), and to route your submission in its “raw” plain-text form to the insurance providers and intermediaries we work with. In doing this, Contact State acts as our “data processor” – it does not use the raw data for its own purposes.

You can find out more about how Contact State uses this data here – https://www.contactstate.com/legal/prospect-notice/517207d6-f65e-450a-995d-f93b7e8cb6a6