Product Terms

We’ve updated this website’s Privacy Notice to reflect a new data privacy law – the General Data Protection Regulation, or GDPR. 

This doesn’t mean that we’re changing the way that we collect or use your personal information when you use this website, but we’ve made clearer to you the information that we collect, how we collect it, what we do with it, and your rights relating to your personal information.

Please don’t hesitate to contact us if you have any questions about the updated Privacy Notice.

 

About these terms and conditions

These terms and conditions (“Terms”) will govern the contract for the supply of OwlDetect to you (“Contract”).  Please read these Terms carefully before ordering OwlDetect.

Please note that you will be asked to agree to these Terms by ticking the box immediately before you click the “Confirm and buy” button at the end of the Summary page on the Website.  By clicking this button, you confirm that you accept these Terms.  If you do not agree with these Terms, you will not be able to order OwlDetect.

You will be provided with a copy of these Terms in the Welcome E-mail. We may occasionally update these Terms in accordance with section C5 below.

These Terms, any Contract between us, and any communications or documents are only in the English language.

YOUR ATTENTION IS DRAWN IN PARTICULAR TO THE SECTIONS CONCERNING OUR LIABILITY TO YOU (SECTION C2), THE LIMITATIONS, EXCLUSIONS AND CONDITIONS APPLICABLE TO THE FEATURES OF OWLDETECT (SECTIONS B1, B2 AND B3) AND HOW YOU CAN CANCEL YOUR SUBSCRIPTION (SECTION A4).

 

Information about us and how to contact us

OwlDetect is provided by CPP Assistance Services Limited, which is a company registered in England and Wales at Companies House. Our registered office is 6 East Parade, Leeds, LS1 2AD, United Kingdom and our registered number is 03180887. Our VAT number is GB 843 1909 25.

You can contact us by email at enquiries@owldetect.com or by calling us on 0330 123 0306 (opening hours Mon-Fri 8am-6pm and Sat 9-1pm). Calls will be charged separately, in addition to the Monthly Fee, and details of our call charges are available on the Website and in your Welcome E-mail.

You can also write to us at OwlDetect, CPP Assistance Services Limited, Holgate Park, York, YO26 4GA.

 

Definitions

Where the following words are used in these terms and conditions, they will have the meanings shown below:

Compromised Data Alert – an alert we send to you in accordance with section B1 to notify you if any of your Monitored Data has been compromised.

Database – a database of compromised personal data which has been collected from unsecure or illegal data trading sites.

Monitored Data – the items of personal data that you register with us after purchasing OwlDetect as may be updated or added to by you on the Subscribers’ Area during your Subscription which we can monitor as part of the Data Monitoring feature of OwlDetect set out at section B1, which can include details such as your national insurance number, driving licence number, email addresses, home and mobile telephone numbers and credit card details.

Month – the period starting on the Start Date and ending on the day preceding the same day of the month in the following month, each successive period of one month during your Subscription (e.g. if your Subscription started on 15 January, your first Month will run from 15 January until 14 February (inclusive)).

Monthly Fee – the amount payable each Month in order to begin and continue your Subscription. Unless varied in accordance with section A3, each Monthly Fee will be the same amount as the first Monthly Fee payable. Details of the Monthly Fee can be found in the Welcome E-mail.

OwlDetect - the collection of service features detailed in these Terms.

Start Date - the start date which is shown in your Welcome E-mail.

Subscribers’ Area - the area of the Website that is available only to you.

Subscription – your subscription to OwlDetect for which you pay the Monthly Fee.

United Kingdom - England, Scotland, Wales and Northern Ireland.

we, us, our, CPP - CPP Assistance Services Limited.

Website – the website at www.owldetect.com.

Welcome E-mail – the e-mail sent under section A2:2 after you have placed an order to receive OwlDetect from us, confirming that our Contract has been concluded. This will contain a copy of these Terms and will confirm other information relevant to the Subscription.

you, your - the person who has purchased, and is entitled to use, OwlDetect, whose name appears in the Welcome E-mail.

 

A: OwlDetect Subscription

 

A1: Conditions of Subscription and your status

By placing an order through the Website, you agree that:

  1. You are 18 years old or over and you are resident in the United Kingdom and are accessing the Website from it.
  2. You will provide us with full and accurate information in relation to your Subscription.
  3. You will give us notice if you change any of the contact details you give us when applying for your Subscription and you will tell us as soon as possible by calling us on the relevant number given in your Welcome E-mail, or using the Subscribers’ Area where applicable.

 

A2: How the Contract is formed between us and who is entitled to use OwlDetect

  1. All orders for OwlDetect from the Website must be placed using the order facility provided on the Website. When you submit an order for OwlDetect, you are offering to purchase OwlDetect from us at the price indicated on the Website. The process is as follows:
    1. select OwlDetect and then proceed to the checkout pages;
    2. you will need to provide certain personal information relating to your order;
    3. once you have submitted this information, you will then be asked to insert your payment details so that we may process payment of your first Monthly Fee;
    4. you will then be taken to the “Summary” page, which will summarise the key information relating to your order for OwlDetect.
    5. Before you submit your order, you will have the opportunity to check and identify any input errors. You may correct those input errors before placing your order. It is your responsibility to ensure that your order is correct before submitting it to us.  Please ensure that you enter complete and accurate information about you.
  2. Once you place your order, our acceptance of your order will take place as described below:
    1. When you click the “Confirm & buy” button you will be redirected to the ’Confirmation’ page, which will let you have your Subscription number. Please note that your Subscription will not start until we have accepted your order (see (3) below).
    2. By submitting an order to us through the Website, and by clicking the “Confirm & buy” button, you confirm that the payment details provided on your order are valid and correct, and that once your order has been accepted and processed by us (see sections (3) to (4) below for information about how and when a legally binding contract is formed between us), payment will be made in full. By placing an order, you confirm that you are the person referred to in the payment details.
    3. Acceptance of an order placed on the Website and the formation of the Contract between you and us will take place when we send you the Welcome E-mail. The Contract between us will only be formed when we send the Welcome E-mail.
    4. If we are unable to supply you with OwlDetect (e.g. because of an error in the price on the Website) we will inform you of this, and we will not process your order. If you have already paid the Monthly Fee, we will refund you the full amount as soon as possible, and in any event within 14 days.
    5. ACCEPTANCE BY US OF ANY PAYMENT MADE IN CONNECTION WITH OWLDETECT DOES NOT CONSTITUTE ACCEPTANCE OF YOUR ORDER. A LEGALLY BINDING CONTRACT IS NOT FORMED UNTIL WE SEND THE WELCOME E-MAIL. WE WILL NOT BE OBLIGED TO SUPPLY THE SERVICE UNTIL THEN.
    6. If at any point there are any problems with your order, please contact us using the details set out in the “Information about us” section above or in the Contact Us page on the Website.
  3. Only you are entitled to use your OwlDetect Subscription.

 

A3: Length of Subscription and payments 

  1. Your Subscription runs from the Start Date and will continue on a month-to-month basis, in return for you paying each Monthly Fee, until you or we cancel your Subscription.
  2. We will collect the Monthly Fee for each Month from the payment card you nominate. If we are unable to collect the Monthly Fee we will notify you. If you do not pay the Monthly Fee for any Month, your Subscription will be suspended. This means that you will continue to receive the data monitoring service described at section B1, however you will not be able to use the other features of OwlDetect. If you subsequently make payment of the Monthly Fee, you will be able to use all the features of OwlDetect again. If payment of any Monthly Fee is not made within the time specified by us to you in accordance with this section, we reserve the right to cancel your Subscription as set out in section A5:1(1) below.
  3. We will advise you of any changes to the Monthly Fee in advance, at least a Month before such changes take effect. If you do not wish to accept our proposed changes to the Monthly Fee, you should cancel your Subscription in accordance with section A4 before the end of the Month prior to the date on which we tell you such changes will take effect.

 

A4: How you cancel your Subscription

 

Your legal right to cancel

  1. You have a legal right to cancel the Contract during the period set out in section A4.2 (“Cancellation Period”) without giving any reason. This means that during the Cancellation Period if you change your mind or decide for any other reason that you do not want to receive or keep the Subscription, you can notify us of your decision to cancel the Contract and receive a full refund. Advice about your legal right to cancel the Contract is available from your local Citizens' Advice Bureau or Trading Standards office.
  2. Your legal right to cancel the Contract starts from the Start Date, which is when the Contract between you and us is formed. Your deadline for cancelling the Contract in accordance with your legal rights ends at the end of 14 days after the Start Date.
  3. To exercise the right to cancel, you must inform us by a clear statement (e.g. a letter sent by post or e-mail). You should exercise your right to cancel by contacting us at the address or e-mail address or by calling us on the number set out in the “Information about us” section above. You may use the attached cancellation form or the cancellation form available on the Website, but it is not obligatory. If you use this option, we will communicate to you an acknowledgement of receipt of such a cancellation on a durable medium (e.g. by e-mail or letter) without delay.
  4. To meet the cancellation deadline, it is sufficient for you to send your communication exercising the right to cancel before the Cancellation Period has expired.
  5. If you exercise this right to cancel within the Cancellation Period, we will make the reimbursement:
    1. without undue delay, and not later than 14 days after the day you inform us of your decision to cancel the Contract; and
    2. using the same means of payment as you used for the initial transaction, unless you have expressly agreed otherwise, and in any event, you will not incur any fees as a result of the reimbursement.
  6. Further information about your legal right to cancel and an explanation of how to exercise it will also be provided in the Welcome E-mail. The model cancellation form will be included in the Welcome E-mail.

 

Cancellation after the Cancellation Period

You also have the right to cancel your Subscription after the end of the Cancellation Period. You can exercise your right to cancel by contacting us at the address or e-mail address or by calling us on the number set out in the “Information about us” section above. If you exercise this right to cancel then your Subscription will be cancelled at the end of the Month in which you tell us you want to cancel. The Monthly Fee will be due for the Month in which you tell us you want to cancel, and you will not be entitled to a refund of any Monthly Fee you have already paid to us. Depending on when in a Month you cancel your Subscription, we may still take payment from you for the next Month on the next scheduled payment date. If this happens we will refund you this payment in full within 14 days.

 

A5: How we may cancel your Subscription

  1. We have the right to cancel your Subscription on written notice to you at any time:
    1. if you do not pay the Monthly Fee on the date it is due; and/or
    2. if, at any time, you give us false information in relation to the purchase of your Subscription.
  2. If we decide to cancel your Subscription for any of the reasons in section A5:1 above, your Subscription will end on the date set out in our notice to you and you will not be entitled to a refund of any Monthly Fees paid to us.
  3. We also have the right to cancel your Subscription:
    1. on written notice to you at any time where it is impossible for us to continue providing OwlDetect as a result of any part of or all of OwlDetect breaching applicable laws or regulations; or
    2. at any time by giving you 30 days’ notice.
  4. If we have to cancel your Subscription for any of the reasons in section A5:3 above, you will receive a refund of the proportion of the Monthly Fee which is applicable to the unused portion of your Subscription for the Month in which we cancel your Subscription.

 

B: OwlDetect features

Following purchase of OwlDetect, you will be able to log into your Subscribers’ Area using the email address you provided and password created during the purchase process.

 

B1. Data Monitoring Service

The data monitoring is carried out by CSIdentity Corporation, a company based in Texas, USA, and its affiliates. CSIdentity Corporation is not a company linked to us and is a separate trading entity but is our subcontractor for the purposes of the data monitoring service feature.

The first time you log into your Subscribers’ Area you will be prompted to input the data that you want to be monitored.  An initial check of the Monitored Data will be carried out against the Database. We will notify you by either email, SMS or both with the results of this search.

To change or add additional information for the data monitoring service to monitor you can log into the Subscribers’ Area and follow the instructions.  An initial check of any additional or updated information you provide will be carried out against the Database and we will notify you by either email, SMS or both if any of the additional or updated data provided is found to have been compromised i.e. matched against the Database.

The Database will be updated daily and following the initial searches described above, we will, during the period of your Subscription, monitor on a daily basis the Monitored Data against the Database.

We will alert you by either email, SMS or both if the data monitoring service described above discovers that your Monitored Data has been compromised, i.e. matched against the Database (“Compromised Data Alert”).

We will also provide a monthly summary by email of any Compromised Data Alerts you have received in that month or confirm that there have been no matches to your Monitored Data found in the relevant month.

 

Limitations, Exclusions and Conditions

  1. The effectiveness of the data monitoring service will depend on the number of elements of Monitored Data given to us. You acknowledge that this feature of OwlDetect can only monitor the elements of the Monitored Data that you provide to us, and cannot monitor any other types of personal information.
  2. There may be restrictions on the number of each type of Monitored Data which you can register with us. Please see the Website and your Welcome Email for details.  
  3. Whilst a large number of websites are searched to create the Database, and we will use reasonable skill and care in providing the data monitoring service, we do not guarantee that all unsecure or illegal websites that may be using your Monitored Data will be discovered and we cannot guarantee to identify all breaches of your personal data online.
  4. The data monitoring service will not be able to inform you where your Monitored Data has been found.
  5. We can only monitor the Monitored Data given to us and will not check the Monitored Data for accuracy.
  6. We cannot guarantee a timescale for generating an alert after your Monitored Data has been identified.

 

B2: Action Plans

Following receipt of a Compromised Data Alert you can log into the Subscribers’ Area which will present you with an action plan detailing suggested steps you can take to help to protect yourself. You can also access high level details of a Compromised Data Alert, and your action plan, by calling us on the telephone number set out in the ‘Information about us’ section above.

 

Limitations, Exclusions and Conditions

  1. We cannot guarantee that all information given to you via any action plan will be applicable to your personal circumstances as information provided will be general, rather than tailored. We will use reasonable care and skill in the provision of such information. To the fullest extent permitted by law, we do not accept any liability for any loss, damage, costs or expenses you suffer as a result of you acting upon the information given to you via an action plan.
  2. The information given to you via any action plan is given for guidance only.
  3. We cannot guarantee that all information given to you via any action plan is up to date or reflects the most recent guidance but we will use reasonable care and skill in the provision of such information.
  4. We cannot guarantee that the Subscribers’ Area will be continually available or free from technical defects or viruses due to the nature of the internet and the possibility of third party interference. We will not be liable for any loss, damage, costs or expenses you suffer as a result of the Subscribers’ Area not being available to you when you want it, or any virus on, or third party interference occurring in respect of, the Subscribers’ Area.
  5. Any action plans are designed to minimise the risks you face from the misuse of your personal data but we cannot guarantee that following the guidance presented or made available will prevent all issues arising or will mitigate all risks.
  6. We cannot provide any offline resolution activities, such as managing a case of identity theft on your behalf.
  7. Calls to us will be charged separately in addition to the Monthly Fee, and details of our call charges are available on the Website and in your Welcome E-mail.

 

B3: Protective Registration

If you receive a Compromised Data Alert indicating that personal data such as passport number and driving licence have been compromised, you can call us on the telephone number set out in the ‘Information about us’ section above, and we will register your personal details with CIFAS (Credit Industry Fraud Avoidance Service) for 24 months to help reduce the risk of your identity being used unlawfully to obtain credit or funds or other products or services in your name. CIFAS is a not-for-profit member association dedicated to the prevention of financial crime.

 

Limitations, Exclusions and Conditions

  1. Calls to us will be charged separately in addition to the Monthly Fee, and details of our call charges are available on the Website and in your Welcome E-mail.

 

C: General conditions

 

C1: Transfer of rights and obligations

  1. Your Subscription is non-transferable. This means that only you are entitled to the rights given to you under the Contract. You may only transfer your rights or your obligations under these Terms to another person if we agree in writing.
  2. We may transfer our rights and obligations under the Contract to another organisation, but this will not affect your rights or our obligations under the Contract.
  3. We may engage someone else to perform all or any of our obligations under this contract on our behalf but only to someone who we reasonably believe is capable of performing them properly. We will notify you if we do this and we will tell you who is performing our obligations.

 

C2: Our liability to you

  1. We only supply OwlDetect for domestic and private use. You agree not to use OwlDetect for any commercial, business or re-sale purpose. We have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
  2. If we fail to comply with these Terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breach of these Terms, or our negligence, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if it was an obvious consequence of our breach or if it was contemplated by you and us at the time we entered into the Contract.
  3. We do not in any way exclude our liability (if any) to you for:
    • personal injury or death resulting from our negligence;
    • fraud or fraudulent misrepresentation;
    • any matter for which it would be illegal for us to exclude or attempt to exclude our liability.
  4. We warrant to you that OwlDetect will be provided to you in accordance with the Terms and will be provided with reasonable skill and care. However, we cannot guarantee that the Website or the telephone support set out at section B2 will be available at all times and will operate uninterrupted and error free but in the event that there any performance issues affecting the Website or the telephone support set out at section B2 we will take reasonable steps to limit any interruption to the service and to resume the provision of the service as soon as possible.
  5. We will not be liable or responsible for any failure to perform the OwlDetect service, or delay in performance of, any of our obligations under a Contract that is caused by an Event Outside Our Control. An “Event Outside Our Control” means any act or event beyond our reasonable control, including without limitation strikes, lock-outs or other industrial action by third parties, civil commotion, riot, invasion, terrorist attack or threat of terrorist attack, war (whether declared or not) or threat or preparation for war, fire, explosion, storm, flood, earthquake, subsidence, epidemic or other natural disaster, or failure of public or private telecommunications networks or impossibility of the use of railways, shipping, aircraft, motor transport or other means of public or private transport.
  6. If an Event Outside Our Control takes place that affects the performance of our obligations under the Contract:
    • we will take all reasonable steps to prevent and minimise any delay; and
    • our obligations under the Contract will be suspended and the time for performance of our obligations will be extended for the duration of the Event Outside Our Control. Where the Event Outside Our Control affects our delivery of the OwlDetect service to you, we will resume performance of the OwlDetect service as soon as the Event Outside Our Control is over.
  7. NOTHING IN THESE TERMS WILL AFFECT ANY OTHER RIGHTS YOU MAY HAVE IN LAW. YOU CAN OBTAIN FURTHER INFORMATION ABOUT YOUR LEGAL RIGHTS FROM YOUR LOCAL TRADING STANDARDS OFFICE OR CITIZEN’S ADVICE BUREAU.

 

C3: Other important terms

  1. If we fail to insist that you perform any of your obligations under the Contract or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations. If we do waive a default by you, we will only do so in writing, and that will not mean that we will automatically waive any later default by you.
  2. The Terms are governed by English law. This means a Contract for the purchase of the Service through the Website and any dispute or claim arising out of or in connection with it will be governed by English law. You and we both agree to that the courts of England will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland or Wales, you may also bring proceedings in Scotland or Wales.

 

C4: Complaints

If you want to make a complaint, please email us at complaints@owldetect.com or phone us on 0330 123 0306*, or write to Complaints, OwlDetect, CPP Assistance Services Limited, Holgate Park, York, YO26 4GA.

Every effort will be made to respond to the complaint as soon as possible. If the complaint cannot be resolved within five working days, you will be sent an acknowledgement letter to keep you informed of progress. We will contact you again within 8 weeks from when you first contacted us with the complaint.

 

C5: Changes to these terms and conditions

  1. We have the right to revise and amend these Terms from time to time to reflect changes in market conditions affecting our business, changes in technology, changes in law, regulation or the requirements of a government or regulatory authority, changes in payment methods and to implement enhancements or improvements to the OwlDetect service, provided that, in the case of revisions to these Terms which implement enhancements or improvements to the OwlDetect service, you will never receive a reduced service to that described to you when you purchased the Subscription.
  2. If we have to revise the Terms as they apply to your order for OwlDetect, we will contact you to give you reasonable advance notice of the changes. If you do not agree with the revised Terms, you will be able to cancel your Contract and receive a refund for any Monthly Fee you have paid for the Month in which the changes take effect.

 

C6: Recording calls

We record all phone calls to us. We do this to provide a record of the instructions we have received, allow us to monitor quality standards, help us with staff training and meet legal and regulatory requirements.

 

C7: Special needs

We are committed to meeting the needs of all our customers, including those with special needs. Hearing and speech-impaired customers who wish to speak to us and have a textphone available can do so by using the Action on Hearing Loss Next Generation Text service. This is available 24 hours a day, seven days a week and allows our customers who find this convenient to contact us via a Text Relay Operator who will relay instructions and other requests verbally to our call centre staff.  Please note that to use the Next Generation Text service, a customer must have access to a textphone or a smartphone with a compatible operating system, tablet, laptop or PC with an internet connection.  To use the Next Generation Text service, just dial 18001 and then dial our number; once the call is connected, a Text Relay Operator will join the call to relay the message.  Our responses will then appear as text on the customer’s textphone, smartphone, tablet, laptop or PC.  For the Next Generation Text service, please call 18001 0344 848 2914.

 

C8: Third Party Rights

This Contract is between you and us. No other person shall have the right to enforce any of its terms.

 

Privacy Notice – How CPP uses your personal information

  1. Information about CPP and Contact Details

CPP takes the privacy of its customers seriously and is responsible for your personal information. CPP’s company details are included in the ‘Information about us and how to contact us’ section of these Terms. CPP is part of the CPPGroup Plc group of companies (“CPP Group”). You can find out more about the CPP Group by visiting www.cppgroup.com.

You can contact CPP:

  • by post at: The UK Compliance Team, CPP Assistance Services Limited, Holgate Park, York, YO26 4GA.
  • by telephone on: 0330 1230306 (Lines are open Mon to Fri 8am - 6pm, Sat 9am - 1pm). Calls cost no more than calls to geographical numbers (01 or 02) and will be included as part of inclusive minutes in your package; or
  • by email at: enquiries@owldetect.com.

CPP has appointed a 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.

You can contact the DPO:

  • by post at: Data Protection Officer, CPP Assistance Services Limited, Holgate Park, York, YO26 4GA; or
  • by email at: DataPrivacy@cpp.co.uk

This Privacy Notice sets out how CPP processes your personal information, in accordance with the General Data Protection Regulation (“GDPR”).

 

  1. What personal information is collected?

CPP may collect and use the following information:

  • your name and contact information (including your address, e-mail address and mobile phone number) and other contact details you provide to CPP;
  • your date of birth;
  • financial information including card payment details;
  • information and data you register with CPP to use the Data Monitoring Service feature of your Subscription, for example your National Insurance Number, your passport number and your driving licence number;
  • information that you provide when you purchase your Subscription;
  • records of any correspondence with you regarding any specific enquiry you make, for example if you call, email or write to CPP. CPP will also hold copies of letters or emails you send or documents you provide in relation to your Subscription, where this is relevant.
  • information about other products and services you obtain from the CPP Group.
  1. How CPP uses your personal information

CPP will only use your personal information when the law allows it to. Most commonly, CPP will use your personal information in the following circumstances:

  • Where it needs to perform the contract for the OwlDetect Subscription it is about to enter into or has entered into with you.
  • Where it is necessary for CPP’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where CPP needs to comply with a legal or regulatory obligation.

Where CPP processes your personal information for direct marketing purposes it will do so on the basis that you have given your consent to the processing of your information for this specific purpose.

  1. What does CPP do with your personal information?

Set out below, in a table format, is a description of all the ways CPP uses your personal information, and which of the legal bases it relies on to do so. The table also identifies what CPP’s legitimate interests are where appropriate.

Note that CPP may process your personal information for more than one lawful ground depending on the specific purpose for which it is using your information. Please contact CPP if you need details about the specific legal ground it is relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity

Lawful basis for processing including basis of legitimate interest

To make decisions on your Subscription.  CPP does not envisage that any decisions will be taken about you using automated means, however CPP will notify you in writing if this position changes

Performance of the contract for the OwlDetect Subscription

To process, provide you with and manage your Subscription and provide OwlDetect

Performance of the contract for the OwlDetect Subscription

To communicate with you by e-mail, telephone or post if you have purchased OwlDetect from CPP, either regarding the purchase or other matters regarding transactions between you and CPP or your customer relationship with CPP

Performance of the contract for the OwlDetect Subscription

To administer the Subscribers’ Area.

 

Performance of the contract for the OwlDetect Subscription

To contact you regarding any specific enquiry you make

Performance of the contract for the OwlDetect Subscription

To collect payments when due

Performance of the contract for the OwlDetect Subscription

Internal record keeping

(a)    Necessary for CPP’s legitimate interests (for running its business)

(b)    Necessary to comply with a legal obligation

To improve its products and services

Necessary for CPP’s legitimate interests (to develop its business and inform its marketing strategy)

Statistical analysis

Necessary for CPP’s legitimate interests (to study statistical trends within the business, to develop its business and inform its marketing strategy)

Fraud prevention

Necessary to comply with a legal obligation

Debt collection

Necessary for CPP’s legitimate interests (to recover debts due to it)

To contact you by e-mail, telephone or post in order to share information with you about products, services and events from CPP and other members of the CPP Group that may be of interest to you

You have consented to this.

To contact you for market research purposes, if you have not objected to such use

Necessary for CPP’s legitimate interests (to understand whether customers value their product, to help it provide a better service to you, and to develop and improve its products and services)

CPP may anonymise personal information and provided individuals are not and cannot be identified from data by itself or when combined with any other data held by us or other persons as relevant, that data will not be subject to this notice or data protection laws. CPP may use anonymised data for analysis of statistical trends such as analysing the number of customers purchasing OwlDetect.

  1. If you fail to provide personal information

Where CPP needs to collect and use personal information by law, to enter into a contract for the OwlDetect Subscription or under the terms of a contract for the OwlDetect Subscription, and you fail to provide that information when requested, CPP may not be able to enter into or perform the contract for the OwlDetect Subscription.

  1. Direct Marketing and Market Research

Where you have consented to this either when purchasing your Subscription or during your Subscription, CPP may provide you with information about CPP Group’s products, promotions and special offers which may be of interest to you. This communication may occur by email or SMS (depending on your selected preferences). CPP will obtain your consent where we are required to do so in accordance with applicable law.

CPP will ensure that any direct marketing or market research that you receive or are contacted about by electronic means will provide a simple means for you to refuse further marketing or market research. For example, in emails it may provide you with an ‘unsubscribe’ link, or an email address to which you can send an opt-out request.

You can change your mind at any time about marketing or taking part in market research by informing CPP using the contact details set out at the top of this Privacy Notice. You can also change your mind at any time about marketing by updating your marketing permissions in the Subscribers’ Area.

In such cases CPP would not necessarily remove all your personal data from its database(s) but would note and respect your changed preferences. CPP will stop any marketing or market research to which you object or withdraw your consent to within a reasonable period, in order to allow sufficient time for the change to be administered.

  1. Who does CPP share your personal information with?

Service Providers

Your personal information will be made available to CPP’s authorised service providers (which will include other companies within the CPP Group which provide services to CPP) and third party suppliers which perform certain services on CPP’s behalf e.g. third party companies who provide aspects of the Subscription as set out above, service providers providing IT support and maintenance, providing hosting services, providing online payment services and providing marketing services.

These service providers may have access to personal information needed to perform their functions on CPP’s behalf but are not permitted to share or to use such information for any other purpose. CPP requires all third parties to respect the security of your personal information and to treat it in accordance with the law.

Third party companies who provide aspects of the Subscription, as set out above.

Cifas

Your personal information may be passed to Cifas in accordance with section B3 above. If you consent, your personal information will be used to create a Protective Registration record about you within the Cifas National Fraud Database, which will then be made available to the members of Cifas and to fraud prevention agencies participating in Cifas. The Protective Registration record will be used to help prevent fraud and money-laundering and to verify your identity. There may be a slight delay when you apply for financial products and services as extra checks are made. Where the risk of fraud is very low some companies may instead accept the application and then contact you separately to ensure the application is from you. Further details of how your information will be used by Cifas when using this aspect of the Subscription, and your data protection rights, can be found by contacting CPP on the contact details set out in paragraph 1 of this Privacy Notice.

Other companies within the CPP Group

 

CPP may share limited personal information with other companies within the CPP Group e.g. to the extent needed for proper management and parental analysis and decision making.

Other Organisations

CPP may also disclose your personal information:

  • In response to a court order, or a request for cooperation from a law enforcement or other government agency;
  • To establish or exercise CPP’s legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;
  • When CPP believes that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property or safety of CPP, other CPP Group members, customers, staff, suppliers or others; to comply with applicable law or cooperate with law enforcement; or to enforce CPP’s terms or other agreements;
  • To prospective or actual buyers in the event that CPP sells any of its business or assets, or to other CPP Group members in the event of a reorganisation.

CPP will not otherwise transfer, disclose, sell, distribute or lease your personal information to third parties unless they have your permission to do so or are otherwise required or permitted to do so by law.

  1. Will my personal information be transferred abroad?

The GDPR permits the export of personal data to other countries subject to the provision of adequate levels of protection for the processing of such personal data. CPP will ensure that if it transfers your personal information outside the EEA, adequate safeguards are put in place to protect your personal information as data protection standards in those countries may differ from those in the EEA.

Please contact CPP’s DPO on the contact details set out in section 1 of this Privacy Notice if you want further information on the specific mechanism used by CPP when transferring your personal data out of the EEA.

  1. How long will CPP hold my personal information?

CPP will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. Please note that by law CPP has to keep basic information about its customers (including contact details, financial information and details relating to Subscriptions) for at least six years after they cease being a customer for tax and legal purposes.

  1. Your rights

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information CPP holds about you and to check that it is lawfully processing it.
  • Request correction of the personal information that CPP holds about you. This enables you to have any incomplete or inaccurate information CPP holds about you corrected. If you think any information CPP has about you is incorrect or incomplete, please contact CPP as soon as you can using the contact details set out below. CPP will correct or update any information as soon as possible.
  • Request erasure of your personal information. This enables you to ask CPP to delete or remove personal information where there is no good reason for CPP continuing to process it. You also have the right to ask CPP to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where CPP may have processed your information unlawfully or where CPP is required to erase your personal information to comply with local law. Note, however, that CPP 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 information where CPP 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. You also have the right to object where CPP are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask CPP to suspend the processing of personal information about you, for example if you want CPP to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that CPP transfer a copy of your personal information to another party, you can contact CPP:

  • by post at: Data Protection Officer, CPP Assistance Services Limited, Holgate Park, York, YO26 4GA
  • by email at: DataPrivacy@cpp.co.uk

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, CPP may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, CPP may refuse to comply with the request in such circumstances.

CPP may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

CPP will try to respond to all legitimate requests within one month. Occasionally it may take CPP longer than a month if your request is particularly complex or you have made a number of requests. In this case, CPP will notify you and keep you updated.

You also have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues. CPP would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact CPP in the first instance.