GUARDIAN MONEY DEALS PRIVACY AND COOKIES POLICY



About this policy


This privacy policy explains how we (OG Enterprises Limited) collect, use, share and transfer your personal data on Guardian Money Deals (“our site”). OG Enterprises Limited is a subsidiary company of Guardian News and Media (GNM) and for the purpose of this privacy policy GNM (and it’s other subsidiaries) are defined as “affiliate companies”. This is separate to how the theguardian.com website uses your personal data. For information on how personal data is used on theguardian.com website, please read the privacy policy here.

Personal data is any information about you by which you are identified or could be identified. This can include information such as:


  • your name, date of birth, email address, postal address, phone number, mobile number; information about your device (such as the IP address, which is a numerical code to identify your device that can provide information
  • information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based); and
  • information relating to your personal circumstances and how you use our site.


Guardian Money Deals advertises insurance and financial services products offered by carefully selected third parties. Our site contains links to the third party websites and services of the third parties whose insurance and financial services are advertised on our site and to other third party sites and services. These websites and services have their own privacy policies. If you follow a link to a third party, you should read the privacy policy shown on that site to see how they use your personal data.



Who we are and how to contact us


The data controller for our site is OG Enterprises Limited, PO BOX 68164 Kings Place, 90 York Way, London, N1P 2AP. This means that we are responsible for deciding how and why we hold and use your personal data.


If you want to contact us, you can find our contact details in the “How to contact us” section below.



Collecting and using your personal data


We collect personal data about you when you use our services and when you browse our site. This information is used to provide the Guardian Money Deals services, and analyse how visitors use our site.



The personal data we collect when you use Guardian Money Deals



We collect personal data when you access our site through cookies or similar technology. When you browse our site we may collect information, including:


  • your IP address - a numerical code to identify your device and which can provide information about the country, region or city where you are based;
  • your browsing history of the content you have visited on our site, including information on how you were referred to our site via another website or how you are referred to other websites via our site; and
  • details of your devices, for example, the unique device ID and browsers used to access our content.


Special categories of data



We will not collect special categories of data - such as information about your race, political opinions, religion, health or sexual orientation - unless you have chosen to provide that information to us.



Information that we receive from our third party partners about your purchases



When you purchase a product or service from one of the third party partners advertised on our site, you will be directed to their site to make the purchase. We may be provided details of your purchase with the third party partner, in order to calculate the commission due to us from advertising those services.



Why we use your personal data



We use the personal data collected through our site for a number of purposes, including the following:



  • To provide you with our services, this includes referring you to the third party providers for purchase of the financial products;
  • To calculate our commission with regard to the purchases that you have made when referred through our site;
  • We also use online advertising to promote our own and affiliate companies services’. This means that you may be shown online advertising for our and affiliate companies services when you are on other websites or social media platforms;
  • For statistical purposes, such as analysing the performance of our site and to understand how visitors use it;
  • To respond to your queries and resolve complaints;
  • For security and fraud prevention and to ensure that our site is safe, secure and used in line with our terms of use; and
  • To comply with applicable laws and regulations.


Legal grounds for using your personal data



We will only use your personal data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and use your personal data. In every case, the legal ground will be one of the following:



  • Consent: For example, where you have provided your consent to receive emails from us.


  • Our legitimate interests: Where it is necessary for us to understand our customers, promote our services and operate our site efficiently for the provision of our services. It is also in our legitimate interest to analyse what content has been viewed on our site, so that we can understand how it is used.


  • Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.


Using children's personal data


We do not aim any of our services directly to children under the age of 18 and we do not knowingly collect information about children under 18.



Security of your personal data


We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our site. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.



Who we share your personal data with


We do not share your personal data with other people or companies (other than affiliate companies) that are not directly linked to us except under the following circumstances:



  • We may reveal your personal data to any law enforcement agency, court, regulator, government authority or other organisation if we believe we need to do so to keep to a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.
  • We may reveal your personal data to any other organisation that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer takes place, we will use reasonable efforts to try to make sure that the organisation we transfer your personal data to uses it in line with this privacy policy.


Any organisations that access your personal data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure they protect your personal data and keep to all privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards.



We will not share your personal data with anyone else for their own marketing purposes unless we have your permission to do this.



International data transfers


Data we collect may be transferred to, stored and processed in any country or territory where one or more of our Guardian group companies or service providers are based or have facilities. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal data that we transfer in line with this privacy policy.



Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:



  • We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data.
  • We may also use specific approved contracts with our service providers that are based in countries outside the EEA. These contracts give your personal data the same protection it has in the EEA.
  • Where we use service providers in the United States, we may transfer personal data to them if they are part of the Privacy Shield scheme, which requires them to provide a similar level of protection of your personal data to what is required in the EEA.


If you are located in the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the EEA.



Keeping your personal data


We keep your data for only as long as we need to. How long we need your personal data depends on what we are using it for. For example, we may need it to use it to answer your queries about our services or where required by law. After this period, we will delete it or make it anonymous by removing all your details.



If we have asked for your permission to process your personal data and we have no other lawful ground to continue with that processing, and you withdraw your permission, we will delete your personal data.



Cookies and similar technology


When you visit our site, we may also collect information from you automatically, by using cookies or similar technologies (“cookies”). A cookie is a small file of letters and numbers that we may set on your device and that transfers information to your device. Other organisations may also set their own cookies on our site. Because of how cookies work, our website cannot access these cookies, nor can the other organisation access the data in cookies we use on our site.



We use the following types of cookies on this site:


  • Essential - These cookies are essential for the operation of our site. This includes cookies that we use so that you can stay logged into your account. If you set your browser to block these cookies, some parts of our site may not work.

  • Performance - These cookies are used to count how often you visit our site and understand how you use our site. We use this information to measure the performance of our site, which allows us to get a better sense of how our users engage with our services and to improve our site so that users have a better experience. For example, we collect information about which of our pages are most frequently visited, and by which types of users. We use Google analytics on our site to report site usage. To opt out, please click this link.

  • Functionality - These cookies are used to recognise you and remember your preferences or settings when you return to our site so that we can provide a more personalised experience for you. Some of these cookies are also set by third parties.

  • Advertising - These cookies are used to collect information about your visit to our site, the content you have viewed, the links you have followed and information about your browser, device and your IP address. We use this information to show you more relevant advertising on our affiliate companies sites (this includes theguardian.com). We may also share this information with third parties for this purpose (you may then also see more relevant advertising on other websites) or we may allow third parties to use their advertising cookies on our sites. This allows us to create groups of people with similar interests to make advertising shown on our affiliate companies sites more relevant. Please click here to opt out.


How you can manage cookies and similar technology



You can manage how cookies are used. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.



You can usually find these settings in the “options” or “preferences” menu of your browser. To understand these settings, the following links may be helpful, or you can use the “Help” option in your browser.





You can switch some cookies off through the Your Online Choices site. You may need to do this again each time you use a different IP address or device.



Your rights with regard to your personal data

You can contact us with regard to the following rights in relation to your personal data:



  • If you would like to have a copy of the personal data we hold on you or if you think that we hold incorrect personal data about you, please write to the Data Protection Officer at OG Enterprises Limited, Kings Place, 90 York Way, London N1 9GU or email dataprotection@theguardian.com. We will deal with requests for copies of your personal data or for correction of your personal data within one month. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
  • Where you have provided us with consent to use your personal data, you can withdraw this at any time.
  • Where applicable, you may also have a right to receive a machine-readable copy of your personal data.
  • You also have the right to ask us to delete your personal data or restrict how it is used. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request. Where applicable, you have the right to object to processing of your personal data for certain purposes, including marketing purposes.


If you want to make any of these requests, please contact us at dataprotection@theguardian.com. We may need to request specific information from you to help us confirm your identity.



Contact us for information about how we use your personal data or complaints

If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact the Data Protection team at OG Enterprises Limited, Kings Place, 90 York Way, London N1 9GU or email dataprotection@theguardian.com.



Complaints will be dealt with by the Data Protection Manager, and will be responded to within 30 days.



If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.



Changes to this Privacy Policy

If we decide to change our privacy policy we will post the changes here. If the changes are significant, we may also choose to email all our registered users with the new details. If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your personal data.





©2018 Guardian News and Media Limited or its affiliated companies. All rights reserved. Registered in England and Wales. No. 908396. Registered office: PO Box 68164, Kings Place, 90 York Way, London N1P 2AP