Who we are
This is the privacy policy for BTR Future LTD (collectively referred to as “BTR Future”, “we”, “us” or “our” in this policy), our sites such as btrfuture.com and our associated apps (“our sites”). Some of our other sites and services have their own policies, which will be relevant to you when you are using those sites and services. BTR Future respects your privacy and is committed to protecting your personal data.
This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. BTR Future is the Controller of data it takes in directly and a Processor of data for its clients and responsible for your personal data. Note:
This privacy policy only relates to data collected by BTR Future directly and any data for which it is a Processor will be used and processed under their Privacy Policies. BTR Future LTD is a company registered in England & Wales (registration number: 15259379) and its registered address is D238, D Mill, Deal Clough Mills, Halifax, West Yorkshire HX3 5AX. BTR Future LTD is registered with the ICO (Registration Number: ZB625333). This Privacy Policy (together with our Cookie Policy, Any Website/Mobile Application Terms and Conditions, Product(s) and Terms & Conditions) sets out the basis upon which we will process personal information that:
• is collected from you when you use this website;
• is collected from you when you apply for/express an interest in/use a product or service offered by or through us;
• we obtain during the provision of that product or service;
• we process as part of a service agreement with one of our clients (which will also be subject to their own privacy policy)
Please read this Privacy Statement carefully, as it contains important information to help you understand our practices regarding any personal information that you give to us. By accessing, browsing or otherwise using the Website or mobile application or using products or services offered by us or through us, you confirm that you have read and agree to this Privacy Statement. If you do not agree with any part of this Privacy Statement, you should not use the Website or mobile application, or apply for/use products or services offered by us and you should not continue to provide your data.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy policy supplements other notices and privacy policies and is not intended to override them. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Contact Details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways: Full name of legal entity:
BTR Future LTD Email address: jon.timmis@btrfuture.com Postal address: D238, D Mill, Deal Clough Mills, Halifax, West Yorkshire HX3 5AX. Telephone number: 07950 107874
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes To The Privacy Policy & Your Duty To Inform Us Of Any Changes
We keep our privacy policy under regular review. This version was last updated on 1st March 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if you believe any personal data we hold on you may have changed during your relationship with us.
What Information We Collect
Personal Data
We may collect personal information (which means any information about an individual whose identity is apparent or can be reasonably ascertained from such information) from you in connection with a service or product provided to you by us on behalf of one our clients, including:
• Identity Data: Including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and proof of identity (including selfies to confirm the proof of identity relates to you, and copies of/details of your driving licence).
• Contact Data: Including billing address, delivery address, email address and telephone numbers.
• Employment/Income Data: Including current and previous employers, nature of work, place of work, transport to/from work, occupations, income, and proof of income.
• Expenditure Data: Including current and expected outgoings, including those from people financially dependent on you or who are identifiable in the information you provide to us/our client.
• Credit Data: Including credit history and publicly held information such as bankruptcies or County Court Judgments.
• Bank Account Data: Including the names and account details alongside transactional data.
• Credit Card Data: Including card numbers.
• Insurance Data: Including previous or current accidents/claims, you may have/have had.
• Technical Data: Including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website or that of our clients/third-party partners.
• Transactional Data: Including details about payments to and from you and other details of accounts, applications or services you have/had had with a client or third-party partners.
• Profile Data: Including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data: Including information about how you use our website, products and services, or that of our clients or third-party partners.
• Marketing and Communications Data: Including your preferences in receiving marketing from our third parties and us and your communication preferences.
• Survey Data: Including your response to surveys done by us, and authorised third-parties
• Video Footage: Including footage captured CCTV footage captured on our premises and where recordings of meetings have been made (with the participant’s agreement).
• Sensitive Data: Including health information regarding a disability, illness or impairment where you inform us of such circumstances. (See our section on Sensitive Personal Data below for further details).
Where information fields are marked as mandatory on any form that you enter information into, you will need to provide such information in order for us to continue with your application/complete the service.
Should you complete mandatory sections of the form, but not complete the whole form, we may use the information provided to contact you to provide support with the service.
If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the service/contract we have or are trying to enter into with you. In this case, we may have to cancel the service/product you have with us, but we will notify you if this is the case at the time.
Aggregated Data
We collect, use and share Aggregated Data, such as statistical or demographic data.
Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.
Third-Party Links
This website and other systems ran and owned by BTR Future may include links to third-party websites, plug-ins and applications, such as social media links. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
If You Fail To Provide Required Personal Data
Where we need to collect personal data by law or under the terms of a contract we have with you/our client, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into. In this case, we may have to cancel any agreement you have with us or be unable to fulfil the request of our client.
How Is Your Personal Data Collected
We use different methods to collect data from and about you including through:
Direct Interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us through our online platform, by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for or purchase/use any product or service from us;
• create an account on our online platform; • subscribe to our service or publications;
• request marketing to be sent to you;
• provide information to us on our website, our mobile application, in writing, through social media, or over the phone (including via call recording);
• register an interest in a job vacancy, or a product and/or service,
• request information or assistance from us;
• enter a competition, promotion or survey;
• make a complaint; or
• give us feedback or contact us.
Automated Technologies or Interactions
As you interact with our website, services, processes or applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third Parties & Publicly Available Sources
We may receive personal data about you from various third parties as set out below:
• Technical Data from analytics providers such as Google based outside the UK and search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment, and delivery services.
• Identity and Contact Data from publicly available sources.
• Credit check report data from credit reference agencies and/or Open Banking account information providers.
• Driving licence data providers.
• Identity and Contact Data, anti-transaction-fraud and anti-money-laundering data providers.
• Other third-party providers relating to credit, fraud, operational, financial and other risk assessments.
Lawful Basis For Processing
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the service you have requested from ourselves, our partners or our clients.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights, do not override those interests.
• Where we need to comply with a legal obligation.
The lawful bases on which we will gather, use and processes your data can be defined as consensual, contractual, for legal obligations or where we have a legitimate interest.
Note: We may process your personal data on more than one lawful basis, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Consent
Consent to the processing of personal data for one or more specific purposes is outlined in detail within this privacy statement – however, in summary, they include, but are not limited to:
• In connection with the introduction and administration of a service you have requested from a client/partner or from us;
• To enable us to review if the service you requested is right for your current/future circumstances;
• To enable us to provide you with information on the current services available to you and to provide you with information on any future services for which you may become eligible;
• For the purpose of introduction and administration of related insurance policies;
• For marketing activities.
We will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Contractual
This is where the processing is necessary for the performance of a contract to which any applicant is a party, in order to take steps at the request of the applicant prior to entering into a contract or for the maintenance of an existing contract.
These activities place requirements on the business to collect and process personal information in order to fulfil its obligations under the introduction and/or fulfilment of any contractual rights, agreements or expectations of any product/service applied for. These may include, but are not limited to:
• Gathering of financial information and performance to understand your creditworthiness or affordability in relation to a product or service;
• Ensure you can make payments on any agreement.
Legal Obligations
This is where the processing is necessary in order for us to adhere to legal and regulatory obligations. These obligations include, but are not limited to:
• HM Government and/or law enforcement agencies for fraud, money laundering and financial crime, detection, investigation and prevention; •
Financial Conduct Authority (FCA) to evidence robust systems and controls;
• Information Commissioner’s Office (ICO) to evidence appropriate technical arrangements for the processing and control of data.
Legitimate Interests
This is where the processing is necessary to enable us to develop and improve the product/service offering or to track whether our existing products/services are functioning as intended.
Any data held for this purpose will be pseudonymised and retained only for the purpose of improving the products and services we offer and will not be used for any other purpose, including communicating directly to you as an individual data subject.
Use Of Your Information
Your information may be used by us in connection with the following purposes:
Service/Product Provision and Internal Processing
This means where we need to use the information for ourselves or on behalf of our clients or partners;
• to register you as a new customer;
• to provide the product or service that you applied for, or elsewise purchased;
• to allow us to consider and process your application for a products or services and/or enable a third party to provide you with a suitable product or service tailored to your needs;
• to evaluate risk in connection with the provision of products or services, such as insurance, credit and credit-related services (including insurance and lending risks). For further information, see the section below on Credit Checking and Automated Decision Making;
• to allow us to provide a quotation and process your application; to enable a thirdparty insurer to provide you with a suitable insurance product or service tailored to your individual needs;
• to confirm, update and improve your customer records;
• to validate claims (e.g., insurance and fraud claims) and to report on the performance of an account;
• to troubleshoot problems with the relevant website, application or service or to customise your experience on the website, application or service;
• to assess what forbearance options are appropriate if you are in financial difficulties;
• to recover debts/money which you owe;
• to provide you with any information on the products or services you hold;
• to administer competitions or prizes;
• to personalise any interactions with you;
• to manage any payments, fees or charges relevant to the product or service you applied for/are contracted for/purchased.
Management of Relationship
This means where we need to use the information for ourselves or on behalf of our clients or partners;
• to manage, analyse, understand and develop your relationship;
• to inform you about improvements to the relevant website, application or service;
• to keep you informed of any of our other/new products and services and identify and market products and services that may be of interest to you, where you have chosen to be made aware of this;
• to assist in any future applications.
Queries or Problems
This means where we need to use the information;
• to respond to any queries, questions or complaints that you may have;
• to contact you if there are any maintenance, servicing or other issues with any product or service you have applied for/have with us;
• to contact you if a form you have started is incomplete.
Training, Service Review and Statistics
This means where we need to use the information;
• for training purposes and/or to enhance or review the product or services we provide;
• to conduct statistical analysis and research (where possible, using anonymised data) to improve our website, products/services, marketing, customer relationships and experiences.
To Verify Your Identity & Prevent Fraud Or Money Laundering
This means where we need to use the information;
• to undertake check before providing and/or services or products to you to confirm your identity;
• to prevent fraud and/or money laundering.
This means where we need to use the information;
• to prevent, investigate and prosecute crime, fraud and money laundering and for auditing purposes;
• if we are obliged to disclose information by reason of any law, regulation or court order;
• for us and/or fraud prevention agencies to detect, investigate and prevent crime and to enable law enforcement agencies to do the same, where they have legal jurisdiction to do so;
• to ensure we abide by rules relating to relevant sanctions and politically exposed person (known as PEP) rules;
• if we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the products/services and financing you have requested or to employ you, or we may stop providing existing services to you;
Note: A record of any fraud or money laundering risks will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing or employment to you.
If you have any questions about this, please contact us on the details provided.
General
This means where;
• the personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering and to verify your identity;
• both we and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime;
• we need to process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and verifying identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the products or services you have requested;
• fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
Other
We may also;
• transfer your information to any entity which may acquire rights in us;
• for any other purpose to which you agree.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us by email at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any application for the provision of service provided by us, our clients or our partners.
How We Might Share Your Information
We might share your information with the following types of third-party suppliers;
• Our subsidiaries or affiliates, for the purpose of managing our customer relationships, administering our business and providing you with information about other products and services which might be of interest to you;
• Insurance companies with which we work in order to process your application/maintain your contractual obligations for any insurance provided.
• Credit and fraud agencies (including Call Credit, Equifax, Experian and CIFAS) to help make decisions (See Section 6: Credit Checking and Automated Decision Making for more information).
• Open Banking providers who provide credit assessment and payment services help make decisions on applications or process payments made to us/made from us via Open Banking (See Section 6: Credit Checking and Automated Decision Making for more information).
• Service providers who need to know the information in order to provide us or you with a product or service, including our third-party service providers who process information/provide services on our behalf to help run some of our internal business operations, including payment systems, email distribution, electronic signature processing, storage of customer documentation, employee service providers, IT services, customer services and for data analytics (using anonymised or pseudonymised data);
• Law enforcement bodies in order to comply with any legal obligation or court order;
• Trade industry bodies who, from time to time, may ask us to provide information about you, such as the Motor Insurance Bureau;
• Where you have been unsuccessful in applying for the product or service with us, but there may be suitable third-party providers who can offer you relevant products/services you may be interested in. In which case, the third-party providers will become the relevant data controller;
• Business advisors to BTR FUTURE, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
• Our investors/potential investors or purchasers of us where the information is specifically required to facilitate that investment/purchase (where possible, using anonymised or pseudonymised data);
• Reputable suppliers of products and services that we feel may be of interest to you where you have agreed to receive such marketing;
• Our chosen insurance companies, where you apply for or have, or have had a product service from us or via us, with regard to any application for insurance, claim or attempted claim;
• Debt recovery agencies, service providers, tracing agents or investigators, solicitors or other agents for the purpose of collecting monies or assets due or outstanding on your account; 1
• Debt purchasers, where have the right to sell performing and non-performing accounts to a third party. However, we will inform you if we do intend to do this on an account you hold with us;
• Entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation;
• In connection to any application for employment in order to validate and assess fitness suitability and eligibility for a role.
Note: If you apply through a third party, we may use your personal information to assess your circumstances and verify the information that you have provided before providing a quote.
6. Credit Checking and Automated Decision Making Whenever you apply for any of our products and/or services or to make decisions about future products, services, and offers that we think you may be interested in the future we and/or some relevant third parties (such as the insurance company we work with) will use automated, manual or part-automated decisioning processes to assess your application including carrying out checks with credit reference agencies (“CRAs”), including: • Checks against data relating to your financial situation and financial history. These checks may be referred to as “hard searches” or “credit application searches” and may be visible to other third parties, such as potential lenders; • Checks against publicly available information such as the Electoral Register, County Court Judgments (CCJs), bankruptcy or repossession information. These checks may be referred to as “soft searches” or “quotation searches” and are visible to only you; • During the lifetime of an agreement with us, we may complete checks of publicly held information such as the Electoral Register, County Court judgements (CCJ’s), bankruptcy or repossession information, as well as data relating to your financial situation and financial history and these may show as “account management searches” or “portfolio management searches” and are only visible to you. We may also ask you to provide current account information via our current regulated Open Banking provider or via Bank Statements. This may also be used as part of an automated, manual or part-automated decisioning process to assess your application or the suitability of the current product/service you have with us/through us, or of any other products/services you may be able eligible for. During this process, we may gather information including, but not limited to: • Your income, including sources of income; • Transactional information on any accounts you share with us, including patterns of spending, type of transaction, and any references/other information shared by your bank; • Details of any missed payments, charges, debit or credit interest; • Payment information (if you choose to make a payment to us via Open Banking or payments are made by us to you via Open Banking). We will use this information to; • Assess your creditworthiness and whether you can afford/sustain any payments for a product/service offered by us/through us; • Verify the accuracy of the data you have provided to us (including identity confirmation); • Prevent criminal activity, fraud and money laundering; • Manage your account(s); • Trace and recover debts; • Ensure any offers provided to you are appropriate to your circumstances. 15 BTR FU TURE We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs. When CRAs receive a search from us, they will place a search footprint on your credit file that may be seen by other lenders. If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them and share this information with them before lodging the application. CRAs will also link your records together, and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link. The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail within the Credit Reference Agency Information Notice (CRAIN). CRAIN is also accessible from each of the three CRAs clicking on any of these links will take you to the CRA’s webpages where you can find details of the CRAIN document: Equifax, TransUnion and Experian. We will only obtain Open Banking data on the specific accounts you choose to share with us. During the sharing of this data, you will be redirected to your bank/finance provider, and you will be asked to complete authentication with your bank/finance provider through their own security systems. We will not, during this process or at any other time, be privy to, obtain, or seek to obtain any information about other accounts you hold with that provider (other than what can be seen via information to choose to share), or about your login/security details with that provider. Access to the information you share with us about your account information via Open Banking may last for as long as you wish this access to continue. After 90 days, if we wish to maintain access to this information, we will ask you for a re-confirmation of your consent to access this information. If you do consent to this, we may access your data for a further 90 days. If you do not consent to this continued access/do not respond to any re-consent, then any access to this information will be revoked (please note that any revocation of access to Open Banking data may impact our ability to assess if the products/services we offer/you have with/through us is appropriate, and these product/services may no longer be available to you and/or products/services you hold may be withdrawn). Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to “international frameworks” intended to enable secure data sharing. Credit scoring is an automated decision. The decision on the provision of credit provided by us is subject to the use of credit scoring, however, may also be subject to a manual review and assessment. If we were to reject your application solely on the basis of a credit scoring system, you can request human intervention and ask us to reconsider your application. 16 7. Data security BTR FU TURE We invest appropriate resources to protect your personal information from loss, misuse, unauthorised access, modification or disclosure, in particular: • We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems. • We restrict access to personal information to our employees, suppliers, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations. • We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 8. Retention of Your Personal Information We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances, you can ask us to delete your data: see Your Rights & Freedoms section below for further information. In some circumstances we may anonymise or pseudonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 17 BTR FU TURE 9. International Transfers We and the other companies processing your data for the purposes mentioned in Section 5 may, from time to time, need to undertake some of the processing in countries outside of the European Economic Area. • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-dataprotection-regulation-gdpr/international-transfers-after-uk-exit/ • Where we use certain service providers, we may use specific contracts approved for use in the UK, which give personal data the same protection it has in the UK. For further details, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-tothe-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/ Different privacy laws may apply in these countries, and you understand and unambiguously agree to the transfer of personal information to these countries and parties. 10. Sensitive Personal Information Sensitive personal data includes information about an individual’s health and other categories of personal information which are closely protected (e.g. criminal convictions). We do not generally process such information unless you have voluntarily provided that information to us (for example, when you have notified us of a health issue). You agree that, to the extent that you have provided us with sensitive personal data, you provided it voluntarily and agree that we can use any sensitive personal data that you provide us to deliver products or services to you and/or determine your fitness to avail yourself of our products or services. Where possible, we shall seek to minimise the collection and use of such sensitive personal data. 11. Marketing Where you tell us you are happy to receive information from us we may send you communications products that we perceive may be of interest to you (including in relation to products and/or services of our partners where we have your agreement). Depending on the contact preferences you select, we will communicate with you by letter, telephone, SMS, email or other electronic means, such as via social and digital media. If, at any time, you prefer not to receive further communications from us in any or all forms (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every e-mail that is sent to you by us or by contacting us (See section on Contact Us below).
Third-Party Websites
Our Privacy Statement does not apply to services offered by other companies or individuals. Our Privacy Statement does not cover the information practices of other companies and organisations that may advertise our services, and that may use cookies, pixel tags and other technologies to serve and offer relevant ads. 13. Email Emails sent via the internet can be subject to interception, loss or possible alteration; therefore, we cannot guarantee their security. Although we will do our best to protect your personal information, we cannot guarantee the security of your data sent by email and, therefore, will have no liability to you for any damages or other costs in relation to emails sent by you to us via the internet. If you would like to contact us, please see the section below or use our contact us page. 14. Children’s Privacy This website is not intended for use by individuals under the age of 18 without the agreement and involvement of a parent or guardian. We do not knowingly collect personal information from individuals under the age of 18. Where we are able to identify that an individual under the age of 18 has used our services (e.g. the individual may have entered a date of birth into the application form), we will ensure no further processing of the individual’s data takes place except for the purpose of erasing the data. 15. Updates to this Privacy Policy Our Privacy Policy applies to all of the services offered by us. We will keep this Privacy Policy under review and make updates from time to time. We will not reduce your rights under Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page, and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). If you do not accept the amended Privacy Policy, you should stop using the Website; this may affect our ability to provide certain products and services to you. Please see the section regarding Your Rights & Freedoms for further information regarding continued processing. 16. Cookies Our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website). To view more information on what cookies we use and how we use them, please review our separate cookie policy.