Privacy Policy


PockEx Privacy Notice

The Privacy Notice is 1.0 and is valid from 00:01hrs on 25th August 2020

PockEx is a trading style wholly owned by Churchill Sloan Limited. For simplicity and transparency purposes, this Privacy Notice is a distillation of the main Churchill Sloan Privacy Notice and specific to processing conducted through the PockEx application and website. Churchill Sloan maintains an organisational Privacy Notice at https://www.churchillsloan.co.uk/privacy-policy/.

PockEx take your privacy very seriously. This Privacy Notice replaces and supersedes all other Privacy Notices associated with PockEx.

Changes to this Privacy Notice.

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notice for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we shall contact you to inform you.

Our Name & Contact Details.

The Data Controller of your personal data is Churchill Sloan Limited. This means that Churchill Sloan decides how your personal data is processed and for what purposes. Our contact details are:

Churchill Sloan
Ribban Court,
Dallam Lane,
Warrington,
WA2 7NG, United Kingdom.

Data Protection Officer Contact Details.

In observance of the General Data Protection Regulation and the Data Protection Act 2018, Churchill Sloan have chosen to establish a Data Protection Officer. Should you wish to contact our Data Protection Officer regarding a data protection matter you can do so by emailing [email protected], or writing to:

Churchill Sloan
Ribban Court,
Dallam Lane,
Warrington,
WA2 7NG, United Kingdom.

Personal data categories we collect

While using this app, we may collect, use, store and transfer different kinds of personal data about you which we have categorised as follows:

  • Identity Data: This includes first name, maiden name, last name, title, and date of birth.
  • Contact Data: This includes home address, previous addresses, email address and telephone numbers.
  • Financial Data: This includes bank account information, account numbers, financial product history, NI number, specific salary details, tax credit/income support data.
  • Marketing and Communications Data: This includes your preferences in receiving marketing from us and your communication preferences.
  • Aggregated Data: This includes statistical or demographic data concerning how you use the app.
  • Special Categories of Personal Data: We will always ask for your explicit consent to record and share Special Category Data. We do not ask you to provide special category data, but the free text and document upload functions of the app may facilitate your providing us with special category data.

For what purposes do we process personal data, and what are the lawful basis’ by which we process data?

Churchill Sloan processes your Personal Data collected through PockEx for the following purposes:

For What Purposes Do We Process Personal Data?
“Churchill Sloan processes your data to…”
What is the lawful basis by which we process the data?
Register and establish a PockEx account; Contract
Communicate with you regarding your PockEx account Contract
Direct market similar or aligned new products and services to you; Consent & Legitimate Interest
Share personal data with specific fulfilment partners so that they may fulfil and/or direct market requested products and services and/or market similar or aligned products and services to our existing customers; Consent
Gather MOT and Car Tax data from DVLA; Consent
Provide functionality for you to upload documentation to the app Consent

What are our legitimate interests for processing your data?

Where we have used legitimate interest as the lawful basis for processing your personal data, we may:

  • Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our current products and services, a soft opt-in exists, and it conforms with the Privacy and E-Communication Regulation (PECR);
  • Request specific consent to share customer personal data with specific fulfilment partners so that they may direct market similar or aligned new products and services to our existing customers;

Sharing your personal data

Churchill Sloan may choose to share your personal data collected in PockEx internally and/or externally to the business. Where we choose to share your information, we shall do so for the following reasons:

  • Where we have your “Consent” to do so. Where we process your data under the consent lawful basis you have the right to withdraw consent. Please refer to “Your Right to Withdraw Consent” section below;
  • Where necessary to fulfil the services and/or products we are “Contracted” to provide to you;
  • Where we have “Legitimate Interest” to do so, including;
    • For the purposes listed in the “What are our legitimate interests for processing your data?” section above.
    • Where one of our registered trading styles and/or current associated businesses provides a product or service similar/aligned with our organisation’s aim to help clients maximise the potential of their data in a fair, lawful and transparent manner that we do not currently provide ourselves. Currently these include:
      • Money Management Team Limited
      • Financial Protection Limited
      • Gladstone Brookes Limited
      • Muldoon Britton Limited
      • Kellner Lenkner UK
      • Synergy Financial Solutions Limited
      • Fylde Office Service Bureau Limited
    • Where an external 3rd Party, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and:
      • Which we reasonably believe would be of benefit to you, and you would reasonably expect to receive
      • Is similar/aligned to our organisation and the services we provide,
      • It conforms with the Privacy and E-Communication Regulation.

      In this case we would contact you using Legitimate Interest to request specific Consent to share your personal information.

      The PockEx app includes the functionality to share your personal data directly with the following service providers. We will always ask for your consent to share your data with these third parties:

      • Fylde Office Service Bureau Limited
    • Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites;
    • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
    • Where we outsource support functions of our organisations to trusted partners. The categories of these recipients include:
Categories Who we use Privacy Notice
Web analytics service providers Google Analytics https://policies.google.com/technologies/partnersites?hl=en-US
App Developer Applikation https://www.applikation.co.uk/privacy-policy/
Social Media Provider LinkedIn
Facebook
Twitter
Instagram
https://www.linkedin.com/legal/privacy-policy
https://en-gb.facebook.com/privacy/explanation
https://twitter.com/en/privacy https://help.instagram.com/519522125107875
Online Adverts Facebook Ads https://en-gb.facebook.com/policy.php
Cookie Provider Cookiebot https://www.cookiebot.com/en/privacy-policy/
Airship Push Notification Provider https://www.airship.com/legal/privacy/
Data Accuracy Support Provider Valid8
Smarter Savings
TBC
Email Delivery Send Grid - Twillo https://www.twilio.com/legal/privacy
Feedback/review service providers; Feefo Holdings Limited https://www.feefo.com/en-au/business/privacy-policy
Consultants CSS Assure
UKGI Limited (Thistle)
Optimum Management
https://www.cssassure.com/privacy-notice
https://www.thistleinitiatives.co.uk/privacy-policy/
TBC
App Analytics Google Firebase

Appsflyer
https://policies.google.com/technologies/partnersites?hl=en-US
https://www.appsflyer.com/services-privacy-policy/
DVLA Registration check DVLA Search https://dvlasearch.co.uk/our-data/

For a full list of suppliers of other suppliers who provide support for all aspects of Churchill Sloan business please refer to Church Sloan Privacy Notice at this https://www.churchillsloan.co.uk/privacy-policy/.

Where we choose and/or have your permission to share your personal data with 3rd Parties we will, where appropriate, ensure that they have signed a contract that requires them to:

  • Abide by the requirements of all relevant data protection and privacy legislation;
  • Treat your information as carefully as we would;
  • Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation); and
  • Allow us to carry out checks to ensure they are doing all these things.

We may, from time to time, disclose your data to and receive from your lenders, underwriters, official receiver/insolvency practitioner and our processors, referrers, external auditors & regulator.

We may have to disclose your personal data with other third parties as set out below. These organisations or bodies will not use your information to contact you. These third parties will be subject to obligations to process your personal information in compliance with the same safeguards that we deploy.

  • HM Revenue & Customs: We’re required to disclose certain data with the HMRC.
  • Financial Conduct Authority (FCA): We’re regulated by the FCA, so we may have to disclose small amounts of data with them for auditing purposes.
  • There may be other regulators and authorities such as Solicitors and Accountants, acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.

Selling your personal data

Churchill Sloan may choose to sell personal data collected through the PockEx application.

You have the Right to Object to us selling your personal data at any time and can do so by informing us by telephone, post or email.

Where we choose to sell your information, we shall do so in the following circumstances:

  • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.
  • For the purposes of generating revenue for our business we may sell your data to the categories of industry listed below where we can demonstrate alignment and similarity:
    • Financial Services

      • Mortgages
      • Life Insurance
      • Home & Contents Insurance
      • Car Insurance
      • Legal Services - Conveyancing, Wills, Trusts etc
      • Mis-Sold Financial Products
      • Banking
      • Financial Products
      • Claims Management
      • Pre-paid Funeral Plans
      • Funeral Plan
      • Private Medical Insurance
      • Breakdown Cover and Recovery Services
      • Travel Insurance
    • Other

      • Charities
      • Lifestyle
      • Mail Order
      • Marketing services
      • Entertainment, Gaming, Leisure
      • Public Sector
      • Fast Moving Commercial Goods (FMCG)
      • Publishing/Media
      • Retail & Lifestyle
      • Gambling and Lotteries
      • Travel
      • Cosmetic Services
      • Health and Beauty
      • Trace, Asset Repatriation and Debt Collection

International Personal Data Transfer - Countries & Organisations.

Churchill Sloan may transfer personal data to countries outside of the UK and/or EEA. Specifically, we use data processors based in South Africa.

If data is transferred outside of the EEA, Churchill Sloan will put in place Standard Contractual Clauses with the Data Controller or Data Processor which contractually obliges them to protect your information to the same standard required by the General Data Protection Regulation and Data Protection Act 2018 post 31 December 2020.

Personal Data Retention Period

Churchill Sloan has the following data retention policies for data collected through the PockEx app:

  • Where you have set up a PockEx account, we shall retain any personal details applicable to the contract delivery for a period of 7 years (name, email, telephone, postal address) after completion of the contract or the last meaningful engagement (a meaningful engagement includes: adding calendar notification, reading a push notification, requesting a referral to a fulfilment provider). During this time, we may contact you using consent and/or legitimate interest to market additional products or services.
  • Where you have uploaded a document to your PockEx account, the document shall be retained until you delete the document or two years after the date of upload whichever comes first. After the two year period, the document shall be erased. You will receive a notification of intended deletion up to 1 month prior to the end of the retention period so that you may download a copy for your records.
  • Where you have inputted a calendar entry into your PockEx account, the entry shall be retained until you delete the entry or two years after the date of entry whichever comes first. After the two years period, the calendar entry shall be erased. The exception to this is entries established as recurring calendar events. Recurring calendar events will remain in the calendar until you erase them or you close your PockEx account.
  • Where you have chosen to input your car registration data and download MOT and car tax information from the DVLA website to the PockEx application, the data shall be retained for 5 years. After 5 years a notification shall be sent to you via push notification and email enquiring whether they wish to keep the vehicle information within the application. Where the notification is not read and/or there is a nil response, the vehicle data will be erased.

The rights available to individuals in respect of the processing

Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:

  • Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about your Right to Access here. In most cases Churchill Sloan will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive (excessive means that you submit a subject access request multiple times for the same or similar information). Fees will not exceed £50. Information will be provided within 28 calendar days from the day you request it. We will take all reasonable steps to verify your identity before providing you with details of any personal information we may hold about you.
  • Your right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about your Right to Rectification here.
  • Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances. You can read more about your Right to Erasure here.
  • Your right to the restriction of processing. You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about your Right to the Restriction of Processing here.
  • Your right to object to processing. You have the right to object to processing if we are able to process your information because the process forms part of our public task, or is in our legitimate interests. You can read more about your Right to Object to Processing here.
  • Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about your Right to Data Portability here.

If you wish to exercise any of your individual rights, you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing [email protected].

Automated decision-making, including profiling.

The PockEx app does not use automated decision making or profiling tools.

Your Right to Lodge a Complaint with the ICO

You have the right to lodge a complaint with the UK’s Supervising Authority: The Information Commissioners Office. Prior to lodging a complaint, Churchill Sloan would like the opportunity to address any complaint you may have.

Should you have a complaint please in the first instance contact our Data Protection Officer by emailing [email protected] or writing to:

Data Protection Officer
Churchill Sloan
Ribban Court,
Dallam Lane,
Warrington,
WA2 7NG, United Kingdom.

If your complaint has not been resolved, you can lodge a complaint with the Information Commissioners Office via email https://ico.org.uk/global/contact-us/email/ or by writing to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire.
SK9 5AF.
Or by telephone on 0303 123 1113.