PRIVACY POLICY
LAST UPDATED 01/06/2020
In order to provide the services and products which you require, we need to process your personal information and share
it with our staff and partners.
This policy is intended to explain, as honestly and clearly as we can, why we need your information, how we will use
it and how we will keep it safe.
Mr Financial Equity Release [MFER] (the “website”) is fully committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed
and used by us. The website is owned and operated by We Breathe Media LTD [WBM] (the “company”). WBM own
all rights, the respective IP, copyrights and trademarks of MFER.
We Breathe Media LTD, company number: 11179160, Registered Address: Capital Tower 91 Waterloo Road, London, SE1 8RT,
ICO Number: ZA021952.
WBM have taken prevision to comply with The Data Protection Act 1998, the Privacy and Electronic Communications Regulations
2003, the EU regulations 2011 and the General Data Protection Regulations of 2018.
Marketing Disclosure
One of We Breathe Media’s marketing websites is Mr Financial Equity Release (the “website”). This site
is designed to help consumers find competitive Equity Release Quotes by connecting them to FCA registered brokers who
offer a range of equity release product options. By registering you are giving your consent to be contacted by our FCA
registered 3rd party brokers. Your registration does not provide consent to share your personal data with any other
3rd parties who are not affiliated with the website.
Additionally you are asked at the point of registration if you would like to register with the wider Mr Group of companies.
This option provides you the opportunity to receive exclusive offers and savings across different product verticals
. If you have not ticked that box the website will not contact you other than at a reasonable time to follow up with
a customer satisfaction email eg 12 months after an insurance quote.
Information we may collect from you can be:
Information that you have provided by completing forms on our site or partner sites when entering a competition or promotion,
e.g.: firstname, lastname, email address, phone number, postcode.
If you contact us, we may keep a record of that correspondence.
Who are We Breathe Media?
We are ‘We Breathe Media Limited’; in this policy we may refer to ourselves as WBM, us or we. We operate
an Affiliate Network and also own a number of websites branded as the ‘Mr Company’, for example, Mr Insurer,
Mr Financial and Mr Automotive, you can see a full list of our sites here.
Regardless of whether you have subscribed through an affiliate partner or a Mr Group website, we will process your information
safely here centrally at WBM mostly in the UK and EU; but in some cases in countries like the USA which provide adequate
protection of your information.
Our business is to help connect our clients with customers like you who may be interested in the services and products
they offer. We do this by asking people to give us their permission to share their information with these brands; we
also ask affiliated partners to help us identify potential customers, and these partners send emails on our behalf.
You can discover more about how we do this in this [how we use your information] section.
We are a limited company registered in England under the company number 11179160 and with the Information Commissioner
where our entry number is ZA451907. If we ever sell the business, or are taken over by another company, your information
will be transferred to that company, but you will receive due notice of the transfer.
Our promise
To connect you with our existing and new clients we need to hold and share your information, but we promise to only do
this where you have given us your permission or you have agreed to our partners contacting you on behalf of our clients.
At any time, you can ask us to stop contacting you, and, as long as there is no legal reason why we cannot, ask us to
remove your information.
Where we are the Data Controller, in other words, where we decide and dictate how your information will be used, we promise
to follow all current data protection legislation for the territory in which we are operating and the current legislation
regarding electronic marketing. Where we act as what is called a data processor, this is where another company engages
us to act on their behalf, we shall only process your information according to their lawful instructions.
The services we offer
We may collect and process your personal data for different reasons.
The two main reasons we process your information is with your consent or using what is called legitimate interests. This
simply means that we are allowed to process your personal details for offline direct marketing purposes as long as our
activities do not override your fundamental rights and freedoms.
Helping clients identify new customers
This is referred to within the marketing industry as ‘customer acquisition’ or ‘lead generation’,
we are usually helping household brands identify new customers for their products and services.
What we collect
The information collected will depend on the exact service offered by our clients but will always entail capturing your
contact details (name, email address, address and phone number), IP address, device used (tablet, iPhone, Windows 10
PC) and other information relevant to that campaign, such as your date of birth if the product were only targeted at
certain age groups e.g. 50 Year old plus for Pension Products. Any additional information will only be captured if it
is relevant to the service, for example, to ensure that you are in a specific country, or to advise you of services
in your locality i.e. enhance and better our service.
To ensure this information is accurate, before it is sent to the client, or added to our system we pass it to a number
of third parties to verify your details, for example, phone number and address. You can see details of these processes
here.
It is very rare that we will collect sensitive data, but it may be necessary for a specific campaign, for example, Private
Medical Insurance for higher risk applicants, for that we needed to collect a very small amount of medical information,
but we would only ever captured this with your permission.
How we collect it
You are in charge of the information we collect about you. You will either be asked to enter your details on the sign-up
page on our websites, or you will be emailed by one of our partners with whom you have a pre-existing relationship and
will be invited to click on a link to our client’s website where you will enter your details directly with them.
Our analytics system will automatically record if you click on any of the links within an email or register as a potential
customer with a client.
Why we collect it
We have been asked by our client to help them identify new clients who may be interested in their product or service.
We would also like your permission to contact you directly and you may also be invited to add your name to our mailing
list. To help us monitor if the service is effective and how many new customers have been generated, we also keep a
note of which hyperlinks you have clicked in both the emails and websites.
Our lawful reason for processing
Our partners, or us, will notify you, via email, SMS, post or sometimes telephone, details of our clients based on your
previous consent with our partner or us. Although where we are just processing your personal data for our own purposes
and especially, for purely telephone or postal purposes, we may rely upon our legitimate interests to keep in touch.
If we, or our clients ever ask you for sensitive personal information such as medical information, then we shall ask
for your ‘explicit’ consent before capturing this.
Where we store your information
Clients will store the information you give them directly on their systems, you will need to check with them where that
information is kept. If you ask to be added to our newsletter or database, we shall keep your information within the
UK. Our tracking software is based in both the UK and Ireland and email broadcasting, audit and backups are held in
the USA but only with organisations who are part of the Privacy Shield Scheme.
Third parties
As we send campaigns on behalf of our clients, they are the Data Controller and will be responsible for how your data
is stored and used. Where you give us permission to add your data to our mailing list, we will only further share that
with other parties, clients, or send information on their behalf, if you give added consent.
To ensure you are a real person we also share your data with third parties to verify some elements of your information,
we do this using some automated decision making processes. You can see details of our clients and tech partners here.
Retention
We will retain your personal or analytical details for 7 years after the last point in which we interacted. Analytical
data is fully or partly anonymised whilst being stored.
We will need to keep such information that enables us to comply with any requests to be forgotten indefinitely.
Other information
To try and advise you only about those products or services in which you are interested, and during the registration
process to ensure that you meet certain criteria, we use several automated processes. For example, we look at which
campaigns you have registered to hear about and advise you about similar products, or a particular service may only
be applicable to people between a specific age range and we will calculate check your age (if given it to us) falls
within this range. Any specific automated decisions will be advised to you in the privacy notice on that particular
page, but are also listed under Tech Partners.
Your data held by We Breathe Media
The data which we hold on you will be used to both supply newsletters from us to you, and to send emails with relevant
information from our clients.
What we collect
The information we hold will depend on what you are happy to give us. However, it will always entail capturing your contact
details (name, email address, address and phone number), IP address, device used (tablet, iPhone, Windows 10 PC), other
information relevant to that campaign, such as [example data]. We will maintain a record of your marketing preferences,
such as to which ‘Mr Company’ website you signed up, the consent wording to which you agreed and your direct
marketing channel preference, for example, postal, email, SMS and so on.
You can change your mind at anytime by emailing compliance@webreathemedia.com or calling our Compliance Officer on 0207
098 9878.
To ensure the information we hold is accurate, before it is added to our system we pass it to a number of third-party
companies to verify your phone number and address.
How we collect it
The data we hold will come directly from you via our website capture form. To ensure that the information came from you,
we shall send an email to the email address provided giving you full details of our service and a link to this privacy
policy. We monitor and record which links within our sites and emails you click on.
Why we collect it
We wish to maintain a list of individuals who have an interest in specific areas or topics so that we can connect our
clients with new customers who may be interested in their product or service. We monitor which hyperlinks you click
to help us better understand in which products you are interested in.
Our lawful reason for processing
In 9 out of 10 cases we are relying on your explicit consent to process your personal information; in these cases, you
can withdraw your consent at any time, and as long as there is no legal reason why we need to retain the data we shall
delete or suppress your information from our system.
In a small number of cases, and where we are emailing you about our own products or service, we can rely on our own legitimate
interests and what is called a soft opt-in. In other words, if you have asked to receive details from one ‘Mr
Company’ website, and we launch a similar ‘Mr’ site, we may send details of the other service to you.
If you ever make an enquiry or complaint to us, or we have ever sold a product or service to you, then we would continue
to hold details on that interaction using our contractual or legal obligations.
Where we store your information
Your data will be managed in secure servers based here in the UK. We also use a combination of email broadcast services
depending on the campaign and some may be based outside of the EU, but we will only use those that can guarantee adequate
protection of your information.
Third parties
We keep you informed about developments using email broadcast companies and to ensure you are a real person we also share
your data with third parties to verify some elements of your information. You can see details of our clients and partners
here. We may also share your data if required to do so by law.
Retention
We will retain your personal or analytical details for 7 years after the last point in which we interacted. Analytical
data is fully or partly anonymised whilst being stored.
We will need to keep such information that enables us to comply with any requests to be forgotten indefinitely.
Other information
In order to try and advise you only about those products or services in which you are interested, and also during the
registration process to ensure that you meet certain criteria, we use a number of automated processes. For example,
we look at which links you have followed and advise you about similar products, or a particular service may only be
applicable to people between a specific age range. We will calculate check your age (if you gave it to us) to ensure
that it falls within this range. Any specific automated decisions will be advised to you in the privacy notice on that
particular website.
Employment & Recruitment
We shall only keep the minimum amount of data on employees and prospective employees which is necessary to protect our
staff and fulfil our legal obligations.
What we collect
We will ask for your full name, contact details, date of birth, nationality, N.I number, qualifications, work experience,
your photograph and photographic proof of right to work in the UK. If you are offered a position we will ask for your
bank details, information regarding your marital status, health and other anti-discrimination information which you
are comfortable giving us, this may include, sexuality, religion and ethnicity. Details of next of kin and other family
members will be requested when necessary to support your employment.
A record of your recruitment interview, payroll, sickness, absence, performance reviews, disciplinaries and other work-related
notes will be maintained. We will also keep logs of activities you perform on our ICT systems and monitor email and
web usage.
How we collect it
The data we hold will come, in the main, directly from you or via a recruitment company, we may also hold information
given to us by other companies for whom you have worked or other employees or Managers. Information will usually come
via application forms, normal correspondence channels through our website or through your day-to-day interactions at
work.
Why we collect it
To consider your application, offer employment, and to comply with our legal obligations, for example, to ensure your
right to work within the UK, collection of ta and health and safety. Medical information and sensitive information are
requested to allow us to assist you in your employment and comply with anti-discrimination laws. We ask for details
of family members for emergency and legal reasons such as complying with our obligations under maternity or parental
leave legislation.
Our lawful reason for processing
The majority of information we ask for is required because the law says we must have it. Where processing of your information
is not strictly necessary for your employment, for example, to use your photo in publicity campaigns, we will ask for
your explicit permission to process.
We rely on our legitimate interests to keep our organisation safe, and our obligation to detect and prevent fraud or
crime, and to this end we monitor computer use, emails, correspondence and web traffic.
Where we store your information
Your data will be kept on our computer and manual files held in the UK.
Third parties
We will share your information with those government agencies that we are required to by law, such as HMRC, the police,
ICO etc. We may need to seek advice from our professional advisors and may pass your information to them under a duty
of confidence. Other sharing includes with our private medical insurer, if requested confidential references for new
employers and if appropriate third-party companies to verify your identity.
Retention
For unsuccessful applicants we will retain your application form for no more than 6 months. For employees and all other
workers, we will hold the information for 7 years after the last point in which we interacted. We shall delete some
information earlier than this time if employment law dictates, for example, disciplinary warnings which have expired.
Other information
Employees should read the WBM Employee Privacy Notice for full details of processing.
Visitors to our website
What we collect
As a website visitor all we capture is your IP address, system type (PC, iPhone, Windows 10 etc) and what pages you visit.
This is done via Google Analytics which is detailed below and in our Cookie Policy. At any time, you can stop the collection
of your anonymous data by Google.
If you, sign up for a service with us or our clients, at that point we shall capture your name, contact and details as
outlined in the ‘Your data held by We Breathe Media‘ [add link] section above. At this point your identity
will be known along with the pages you have visited.
Some of our cookies allow us to present you with adverts about our service on other sites. This is normally referred
to remarketing or retargeting.
How we collect it
Data is collected by way of cookies placed on your device – you can remove these at any time.
Why we collect it
Some cookies are necessary to allow our sites to operate successfully. We use remarketing to remind you of our services
in the hope that you will sign up for one of our sites.
Remarketing cookies are managed by third party companies, and they are listed in our partners link below here. The information
which they capture is partly anonymous, in that they only have your IP address and pages visited. If at some point you
sign up to one of our sites, then only then would your identity be known.
Our lawful reason for processing
We are relying upon our legitimate interests to use cookies otherwise the sites could not run and capture anonymous or
partly anonymous data to understand how the sites are working and which pages are being viewed. We ask for your consent
to use tracking cookies.
Where we store your information
We store details of your activity on our cloud server in the EU. Google Analytics and our remarketing partner are based
within the EU.
Third parties
Information from tracking cookies will be managed by third party companies, more information can be found in our cookie
policy. Our website developers, IT support and marketing consultants may also access this part-anonymised data.
Retention
Anonymised data will be kept indefinitely, other information will be deleted 3 years after the last interaction with
the client. We will need to keep such information that enables us to comply with any requests to be forgotten for an
indefinite period.
Children
We only target, and knowingly process details of individuals of 18 years of age and older. Unless data is entered accidently
or maliciously by a user, client or other third party, we will never deliberately process data of children.
Security
At all times we, and the processors for which we are responsible will process your information in line with current UK
data protection and electronic marketing legislation. We will put in place sufficient organisational and technical measures
to keep your information safe, and where possible store your information in the UK or EU.
All of our staff are trained in data protection and we also have in place confidentiality agreements to further protect
your information. We try, as far as is possible, to ensure that all partners have similar protections in place.
Occasionally we may use a service, such as an email broadcast platform, which is hosted outside of the EU, but we will
take all due care to ensure the safety and security of your information. We shall only use companies outside of the
EEA if the EU has deemed them to have adequate data protection measures, or in the case of the USA are part of the Privacy
Shield Scheme.
Automated processing
We use a number of automated processes to validate details given to us, check certain criteria, for example age or eligibility,
and to understand which products are of interest to you.
These automated decisions do not affect your fundamental rights, nor affect you in a legal way but are listed under Tech
Partners here.
See your rights below for objecting to any processes.
Your Rights
The Data Protection Act and GDPR affords Data Subjects (that is people whose information we capture) certain rights and
these are listed below for your convenience: -
You have the right to access a copy of the personal information we hold about you. You can do this by phone, in writing
or by email to the WBM contact details below. We would be happy to help, we will just have to verify your identity before
we can proceed.
You have the right of rectification to amend or update your personal information and ensure we maintain accurate and
up to date records and or data about you.
You have the right to erasure, also known as ‘the right to be forgotten’.
The broad principle underpinning this right is to enable an individual to request the deletion or removal of personal
data where there is no compelling reason for its continued processing by us or our partners.
You have the right to ‘block’ or suppress the processing of your personal data. Processing of your personal
information may be restricted in the event it is no longer essential to support the use of services provided to you
and/or not part of any contractual, legal or financial requirement to do so.
WBM are permitted to store the personal data, but not further process it. We may retain just enough information about
you to ensure that any restriction is respected in future.
You have the right for data portability which allows individuals to obtain and or reuse their personal data for their
own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment
to another in a safe and secure way, without hindrance to usability.
You have the right to object to the processing of your personal information where we are processing this based on your
consent, our legitimate interests or the performance of a task in the public interest or exercise of official authority
including profiling activity, direct marketing including profiling activity; and processing for purposes of scientific
and or historical research and statistics.
You have right to be made aware of any automated decision-making, that is decisions made on or about you without any
human involvement, and/or profiling of your personal information by WBM.
- We use an automated process to validate details given to us, check certain criteria, for example age or eligibility,
and to understand which products are of interest to you. These automated decisions do not affect your fundamental rights,
nor affect you in a legal way but if you would like to know more, please see the section on automated processing.
You have an absolute right to ask us to stop sending you direct mail or email.
For some processing you will have given us permission to process your information, and in these cases, you can withdraw
your consent at any time. In certain situations, these rights may not apply, for example if you entered into a membership
minimum term contract, we may have to write to you about your membership even if you asked us previously not to, but
we would not send you direct marketing.
To activate any of your rights contact us on the details below.
Cookie Policy
Last Updated 01/01/2020
Cookies are small files of letters and numbers stored on your browser or device that enable the cookie owner to recognize
the device when it visits websites or uses online services. The website you visit may set cookies directly, known as
first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies. While we may automatically
use some cookies that are strictly necessary to provide the services you request or enable communications, we request
your consent for all of our other cookie uses.
Types of Cookies We Use
Strictly necessary cookies. Our website requires the use of these cookies to properly operate or provide necessary functions
relating to the services you request. They include, for example, cookies enabling you to securely log into our website
login to our affiliate network, navigate our site, or sign up for newsletters.
Analytical/performance cookies. These cookies allow us and our third-party partners such as Google, to recognize and
count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve
how our website works by, for example, ensuring that users can easily find what they need on our website. These cookies
generate aggregate statistics that are not associated with an individualized profile.
Functionality cookies. These cookies enable helpful but non-essential website functions that improve your website experience.
By recognizing you when you return to our website, they may, for example, allow us to personalize our content for you,
remember your username, or remember your preferences (for example, your email address to facilitate quicker registration
to our websites.) These cookies may enable visitor identification across websites and over time.
Advertising, tracking or targeting cookies. These cookies enable different advertising related functions. They may allow
us to record information about your visit to our website, such as pages visited, links followed, and videos viewed so
we can make our website and the advertising displayed on it more relevant to your interests. These cookies may enable
visitor identification across websites and over time.
We may also share the information with third parties for similar purposes.
Third-party cookies. Our website may contain helpful but non-essential features or plug-ins enabling third party services
that use cookies, such as social network connectors, maps, advertising networks, or web traffic analysis services. These
cookies may enable visitor identification across websites and over time. We do not control the third party’s use
of those cookies. Please review each party’s cookie disclosure before consenting to this use category here.
Our Privacy Policy (https://www.webreathemedia.com/privacy-policy) describes our practices for any personal data that
our first-party cookies collect, store, or use, including our legal basis for processing personal data. We rely on our
legitimate interest (link to ICO site) to process essential and functional cookies, and your consent for other cookies.
Except for strictly necessary cookies, all first-party cookies set by this site will not expire after your last website
visit. Third-party cookie expiration periods are set by their respective owners.
Please see our cookie table for a list of the individual first-party and third-party cookies potentially used on this
site and their specific purposes.
Cross-Border Data Transfers
The cookies we use may process, store, or transfer personal data in and to a country outside your own, with privacy laws
that provide different, possibly lower, protections. You consent to this transfer, storing, or processing when you consent
to our cookie use. We are based in the United Kingdom, please review the third-party cookie provider’s policy
to learn more about its location.
Your Cookie Choices
Please visit our consent manager tool [URL] to make or manage your cookie use preferences.
Most web browsers allow you to directly block all cookies, or just third-party cookies, through your browser settings.
Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site
operation.
Changes to Our Cookie Uses
We will post any changes to the way we use cookies on this page and indicate on our website(s) that we updated this cookie
notice. If the changes materially alter how we use cookies, we will post a notice on our website and request your consent
for the materially different use.
Please check back frequently to see any updates or changes to our cookie use notice.
Contact Information
Please email compliance@webreathemedia.com any questions, comments, or requests regarding this cookie use notice. Alternatively,
you can send a postal letter with your enquiry to the address below:
The Compliance Officer
WE BREATHE MEDIA LIMITED
Capital Tower
91 Waterloo Road
London, SE1 8RT
Cookie Table
Cookies Used on We Breathe Media and the Mr Group branded Websites:
The following table lists all cookies potentially in use on the We Breathe Media and Mr Brand websites. We will update
this table as our website changes and evolves, so please check back frequently to review any new cookie uses. Visit
our We Breathe Media Cookie Policy for more information and choices about our cookie use, including our contact information
and complaint procedures.
Last Updated 01/01/2020
|
Cookie Category
|
Cookie Name and Owner
|
Purpose
|
More information
|
|
[Necessary]
[Analytical or Performance]
[Functional]
[Advertising or Tracking]
[Third-Party]
[OTHER COOKIE CATEGORY]
|
[COOKIE NAME]
[COOKIE OWNER]
|
[DESCRIPTION OF THE PURPOSE FOR WHICH THE COOKIE IS USED]
[This cookie [is essential for our site to/enables us to]:
- [Estimate our audience size and usage pattern.]
- [Store information about your preferences and therefore customize our site and provide you with offers targeted
at your individual interests.]
- [Speed up your searches.]
- [Recognize you when you return to our site.]
- [Allow you to use our site in a way that makes your browsing experience more convenient, for example, by allowing
you to store items in an electronic shopping basket between visits. If you register with us or complete our online
forms, we will use cookies to remember your details during your current visit, and any future visits, provided
the cookie was not deleted in the interim.]
|
[Session Cookie/Persistent Cookie that expires [DURATION]].
[SAMPLE OF INFORMATION STORED OR TRANSMITTED BY THE COOKIE]
[LINK TO EXTERNAL INFORMA
|
Changes to This Privacy Notice
Businesses develop over time, and we reserve the right to update this Privacy Notice at any time, and we will provide
you with notice of any significant changes. If we would like to use your previously collected personal data for different
purposes than those we notified you about at the time of collection, we will provide you with notice and, where required
by law, seek your consent, before using your personal data for a new or unrelated purpose.
We may process your personal data without your knowledge or consent where required to do so by law, or instructed by a
UK, or in certain circumstances, EU court.
Contact details
If you have any questions or concerns do not hesitate to contact us:
The Compliance Officer
WE BREATHE MEDIA LIMITED
91 Waterloo Road
London, SE1 8RT
- 0207 098 9878
- compliance@webreathemedia.com
ICO Registration Number: ZA451907
Companies House Registration number: 11179160 (registered in England)
Complaints Procedure
We hope that the service and experience provided by We Breathe Media Ltd is a good one, however, we do realise that matters
don’t always go as planned, and therefore this policy explains how We Breathe Media will deal with any concerns
you may have about the service received.
How do I make a complaint?
If you do have a concern or complaint, please contact us as soon as you are aware of the problem, in order for this to
be addressed. You can contact us by:
Telephone: 0207 098 9878
Email: info@webreathemedia.com
Post:
We Breathe Media Complaints
Capital Tower
12th Floor
91 Waterloo Road
London
SE1 8RT
Please include the following information:
Your full name
Reference number (if you have one)
Contact telephone number
Contact email address
Full details of your concern
What happens next?
We will send you a letter acknowledging receipt of your complaint within five days of our receiving the complaint, enclosing
a full copy of the complaints procedure and advising you who will be responding to the complaint. We aim to resolve your
complaint fully within 21 days of sending you the acknowledgement letter.
What happens if I am unhappy with the response?
The matter will be referred to our Managing Director, Piers de Grouchy, who will consider the complaint further.
Information Commissioners Office
If you are unhappy with how we have processed your information, you have the right to lodge a complaint with the Office
of the Information Commissioner, contact details below.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Helpline: 0303 123 1113 (local rate) or +44 1625 545 745
