Privacy Policy
1. Purpose of this privacy notice
This privacy notice aims to provide information on how Rawaaj collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase and/or use a product or service.
This website is 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 notice or fair processing notice we may provide 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.
Controller
Rawaaj is the controller and responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this privacy notice). Its registered office is 36 Moreton Avenue, Isleworth, TW7 4NW. The Company owns the information collected on the website.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the email address: [email protected]
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in May 2018. This privacy policy may change from time to time so please check it periodically.
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website 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.
2. The Data We Collect About You
Personal data, or personal information, 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 follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, and gender.
• Contact Data includes billing address, correspondence address, email address, and telephone numbers.
• Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Previous and current queries information about previous and current queries.
• 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.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our website, products, and services.
• 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 for any purpose. 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 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 offenses.
If you fail to provide personal data
Where we need to collect personal data to be able to provide our services and you fail to provide that data when requested, we may not be able to provide you with our product 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.
3. How Is Your Data Collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data, and Previous and current details by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
(1) purchase our products or services;
(2) create an account on our website;
(3) subscribe to our service or publications;
(4) request marketing to be sent to you;
(5) enter a competition, promotion, or survey; or
(6) give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
(1) Technical Data from analytics providers such as Google based outside the EU.
(2) Contact, Financial and Transaction Data from providers of technical, payment, and delivery services based inside the EU, such as PayPal, RoyalMail.
(3) Identity and Contact Data from publicly available sources such as postal services inside the EU.
4. 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 use your data to provide you with our products and services.
• 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 or regulatory obligation.
Please refer to the Glossary 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 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.
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.
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 in the table below.
| PURPOSE/ACTIVITY | TYPE OF DATA | LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST |
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| To confirm payment for products/services | (a) Identity (b) Contact (d) Transaction | (a) Provide our products/services. (b) Necessary for our legitimate interests (to determine the likely risk profile and appropriate insurance product) |
| Customer Administration | ||
| To process and deliver your order including (a) Manage payments, fees, and charges (b) Collect and recover money owed to us (c) Process payment and refunds. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) To provide you with our products and services. (b) Necessary for our legitimate interests (to recover debts due to us) (c) To operate a seamless payment/refund system. |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) General client care, including communicating with customers | (a) Identity (b)Contact (c)Profile (d) Marketing and Communications (e) Usage | (a) Providing you with our products and services. (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 and to correspond with customers in order to facilitate the placing of orders and claims under insurance policies) |
| Order / Contract Processing | ||
| Managing orders / contracts | (a) Identity (b) Contact (c) Profile (d) Transaction (e) Previous and current claims | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to assist our customers in assessing and making claims) |
| Renewals | ||
| Contacting customers in order to arrange delivery of our product and services. | (a) Identity (b) Contact (c) Profile (d) Transaction | (a) Provide you with our products and services. (b) Necessary for our legitimate interests (to correspond with customers to facilitate the delivery of our product and services) |
| Consultancy Services | ||
| To provide consultancy services, including providing advice, general client care, and evaluation of risk | (a) Identity (b) Contact (c) Profile (d) Transaction | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to correspond with customers in order to assess the risks and provide the agreed consultancy services) |
| Website and Marketing Activities | ||
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data) | (a) Identity (b) Contact (c) Technical | (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 reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | 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 website, products/services, marketing, customer relationships, and experiences | (a) Technical (b) Usage | 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 | (a) Identity (b) Contact (c) Technical (d)Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| Legal and Regulatory | ||
| Complying with our legal or regulatory obligations | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile (f) Usage (g) Marketing and Communications | (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to take pre-emptive steps to ensure legal and regulatory compliance) |
Marketing
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.
Third-party marketing
We do not pass on your details outside our Company.
Opting out
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or 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 product/service purchase, warranty registration, product/service experience, or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.
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.
5. Disclosures of Your Personal Data
We may have to 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 as set out in the Glossary.
• 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. 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.
6. International Transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data Retention
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period or to, or such information is necessary to resolve disputes and enforce our agreements. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
8. Our Commitment to Security
Rawaaj employs a variety of security technologies and procedures designed to help prevent unauthorized disclosure of, access to, and use of Information that Rawaaj collects or receives. However, Rawaaj cannot guarantee the security of your Information.
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.
9. Children’s Privacy
We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age, and no part of the Service is directed to children under the age of 16. If you learn that your child has provided us with personal information without your consent, then you may alert us at [email protected]. If we learn that we have collected any Personal Information from children under 16, then we will promptly take steps to delete such information.
10. Do Not Track
Some web browsers incorporate a “Do Not Track” feature. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our website does not currently respond to such signals.
11. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
• 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 your 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 to continue 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 your fundamental rights and freedoms. You also have the right to object to 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 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 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.
• Right to 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.
If you wish to exercise any of the rights set out above, please contact us.
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.
What we may need from you
We may need to request 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). 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.
12. Updates to this Privacy Policy
We will post any adjustments to this Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through our Service, we will notify you through our Service, by email, or other communication.
13. Glossary
Lawful basis
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.
Providing you our products/services means processing your data where it is necessary for the performance of a contract to which you are a party or to deliver a specific product/service as outlined on our website.
Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Third parties
External third parties
- Service providers acting as processors in the United Kingdom who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Service providers acting as processors in the United Kingdom who provide payment gateway solutions.
