Settld Privacy Policy
This Privacy Policy explains how we collect, protect, use and share information that identifies, relates to, or could be reasonably linked, directly or indirectly, with a particular identified or identifiable natural living or deceased person which you provide to us, or the user personal data which we collect from you whilst you use Kind Call Ltd T/A Settld Services (the “Personal Data”).
Please note that certain information, statements, data, and content (such as photographs) which you may submit to us are likely to reveal your gender, ethnic origin, nationality, age, and/or other personal information about you. You acknowledge that your submission of any information, statements, data or content to us is voluntary on your part and that we (or any of our relevant service providers) may process such information, within the provisions of this Privacy Policy.
By viewing, using, or submitting information through our website and or our apps, you are indicating that you agree to be bound by the terms of this Privacy Policy. This Privacy Policy does not apply to any third-party websites, services, or applications, even if they are accessible through our Services.
Our aim is responsible and secure handling of Personal Data, balancing the benefits of activities like research and data analytics to improve our products and service delivery, with our other commitments, including fairness, transparency, and non-discrimination.
For the purposes of the Data Protection Act 1998, and the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), to the extent it is applicable, the data controller and data processor is:
Kind Call Ltd T/A Settld,
Building 5, Floor 9
Exchange Quay
Manchester
M5 3EF
legal@settld.care
Any reference herein to ‘we’ means Kind Call Ltd T/A Settld unless the context otherwise requires. Any changes to this Privacy Policy in the future will be posted on our website and, if you are a contractual client of Settld, notified to you by email. Please check back frequently to see any updates or changes to this Privacy Policy. Any Personal Data that is collected via the Settld Services or otherwise, is covered by the Privacy Policy in effect at the time such information is collected.
This Privacy Policy covers matters pertaining to your personal information:
1. WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND WHERE DO WE GET IT FROM
2. WHAT IS OUR LEGAL BASIS FOR HANDLING PERSONAL INFORMATION
3. WHAT METHODS OF DATA COLLECTION DO WE USE
4. WHAT DO WE USE PERSONAL INFORMATION FOR
5. WHO DO WE SHARE THE PERSONAL INFORMATION WITH
6. HOW LONG IS THE PERSONAL INFORMATION KEPT FOR AND HOW IS IT KEPT SECURE
7. WHERE IS THE PERSONAL INFORMATION STORED AND SENT
8. IS THE PERSONAL INFORMATION USED TO MAKE AUTOMATED DECISIONS ABOUT YOU OR TO PROFILE YOU
9. WHAT ARE YOUR RIGHTS
10. WHAT COOKIES ARE USED ON OUR WEBSITE
11. DO WE RECORD CALLS AND MONITOR EMAIL COMMUNICATIONS WITH US
12. HOW CAN YOU TELL US ABOUT YOUR MARKETING PREFERENCES
13. WHO CAN YOU COMPLAIN ABOUT THE USE OF YOUR PERSONAL INFORMATION
14. WHEN WAS THIS PRIVACY POLICY LAST UPDATED
1. WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND WHERE DO WE GET IT FROM
Your Personal Data includes personally identifiable information, about yourself or about other living and deceased individuals you submit to us or which we have collected from publicly-available sources (the “Personal Information”) and information about your use of Settld Services, and the devices you use to interact with us, from which you may be identifiable.
In detail:
Your Personal Information
We use the words Personal Information
to describe information about you and other living and deceased individuals (for example, your client, your partner or other members of your family, or of your client’s family), and from which you or they are identifiable. All references to Personal Data, hereunder, shall include Personal Information as defined in this section.
Personal Information can be obtained from a variety of sources, including:
• Account statements, bills, and other forms;
• Telephone calls, emails, meetings and other communications;
• Service providers, witnesses, medical professionals, banks, the courts, insurance companies, and other third parties;
• Our website (the Site);
• The software applications made available by us on computers, smartphones and other mobile devices (the App); and
• Our social media pages, other social media content, tools and applications (our Social Media Content).
In this Privacy Policy, we refer to the Site, the Apps and Social Media Content together as Settld Services.
Unless otherwise indicated, the Settld Services are not intended for use by individuals under the age of eighteen (18), and we request that if you are under eighteen (18) you do not provide Personal Information through the Settld Services.
We can obtain Personal Data about you directly or from third parties. For example, a local authority, solicitor, or representative of the NHS may, where authorised to do so, provide Personal Information about you and you authorise us to obtain and process such Personal Information.
Please note:
Personal Data concerning persons who are deceased is not protected by GDPR and not covered by the definition of Personal Information in this Privacy Policy. We will nevertheless process Personal Data about you or any deceased person you may represent (e.g. as an executor, solicitor, personal or other representative of the deceased and/or their estate). Before providing us with Personal Information about another living individual and or any other Personal Data about them or their affairs you must (unless we agree otherwise): (a) inform living individuals of that fact and about the content of this Privacy Policy and any other applicable privacy notices provided to you by us; (b) obtain such living persons permission to share their Personal Data (as applicable) with us in accordance with this Privacy Policy and other applicable privacy notices; or (c) in the case of Personal Data concerning deceased persons, have the legal authority to represent such persons and or their estate and, as appropriate, act on act of their behalf/on behalf of their estate.
The Personal Data we collect and hold depends on our relationship with you and any persons you may represent.
It will often include:
• Personal Information relating to:
◦ Contact details
◦ Identification
◦ Administration of your household, digital and subscription services
◦ Finance and banking
◦ Marketing preferences
◦ Use of Settld Services
• User and device data including:
◦ Internet browser and electronic device information;
◦ App usage data;
◦ Information collected through cookies, pixel tags and other technologies;
◦ Demographic information; and
◦ Data grouped together so that it is not possible to link the data to a particular individual, known as aggregated data.
In detail:
The Personal Data we collect and hold about you and other individuals will differ depending on our relationship, including the type of communications between us and the products and services we provide.
Personal Data collected from or through you
As we are in the business of providing assistance in closing and or changing accounts and related services, the Personal Data we hold and process, depending on our relationship, includes:
Type of Personal Data |
Description |
|---|---|
| Contact Information | Name, address, email, and telephone number. |
| General Information | Gender, marital and family status, date and place of birth, and physical characteristics (appropriate to the circumstances). |
| Education and Employment Information | Educational background, employer details and employment history, skills and experience, professional licences, memberships, and affiliations. |
| Utility and Subscription Services Information | Account numbers, relationship to account holder or other relevant individual, date, and cause of changes to accounts and personal information. |
| Government and Other Official Identification Numbers | Social security or national insurance number, passport number, tax identification number, driver’s licence number, or other government-issued identification number. |
| Financial Information and Account Details | Payment card number (credit or debit card), bank account number, or other financial account number and account details, account log-in information and passwords for accessing financial accounts, and Settld Services. |
| Medical Condition and Health Status | Current or previous physical, mental or medical condition, health status, injury or disability information, medical diagnosis. |
| Other Sensitive Information | Information about any other organisations that you or your client is a member of. This might include political organisations or trade union membership. |
| Telephone Recordings | Recordings of telephone calls with our representatives and call centres. |
| Photographs and Video Recordings | Images (including photographs and pictures) or video recordings created in connection with our business activities, including for administration or for other relevant purposes as permitted by law, as well as CCTV recordings captured by equipment on our premises. |
| Information to Detect, Investigate, or Prevent Crime, Including Fraud and Money Laundering | We can collect, hold, and share information about you or your client’s previous dealings with the intention of the detection, investigation, and prevention of fraud, money laundering, and other criminal activities. |
| Information Enabling Us to Provide Products and Services | Location and identification of property address, vehicle licence plate or identification number, age categories of individuals for whom we will make account changes, history of disputes, civil or criminal proceedings or formal investigations involving you. |
| Marketing Preferences, Marketing Activities, and Customer Feedback | Marketing preferences, information relating to competition, prize draw or other promotion entry, or responses to voluntary customer satisfaction surveys. To improve our marketing communications, we will collect information about interaction with, and responses to, our marketing communications. |
| Online Activity Information | We will receive Personal Information about you when you view or use Settld Services; this includes your Log Data such as your Internet Protocol (IP) address, browser type, operating system, the web page that you were visiting before accessing the Settld Services, the pages or features of the Settld Services which you browsed and the time spent on those pages or features, search terms, the links on the Settld Services that you clicked on and other statistics, when provided by you, your social media account identifier and profile picture, other online identifiers (to the extent that they are Personal Information), and other Personal Information that you provide to us or that we collect, including data relating to your use of our website and our Apps or via email or other electronic means. If you choose to connect your social media account provided by another social media service provider to your account on any of the Settld Services, Personal Information from your other social media account will be shared with us, which includes Personal Information that is part of your social media account profile, or the profiles of your friends and other connected individuals. Like many website owners and operators, we use automated data collection tools such as Cookies to collect user and device data. |
The processing of Personal Data of our users takes place periodically and exclusively after the consent of the user. An exemption is in force for such cases, where a prior obtaining of a consent is not possible for actual reasons and where the processing of the data is permitted by law.
Data collected through third parties
2. WHAT IS OUR LEGAL BASIS FOR HANDLING PERSONAL INFORMATION
When we obtain a consent from the person in question to process their personal data, Art. 6 para. 1 lit. a of the European General Data Protection Regulation (GDPR) serves as the legal basis. In terms of processing personal data, which is necessary to fulfil a contract, whose signatory party is the person in question, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This applies also to processes that are necessary to execute pre-contractual measures. As far as processing of personal data is necessary to execute legal obligations, Art. 6 para. 1 lit. c serves as the legal basis.
In case vital interests of the person in question or any natural person require us to process personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
As far as the processing is necessary to protect a legitimate interest of our company or of a third party and the interests, civil rights and fundamental liberties of the person in question outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.
References to a law of the European Union includes a reference to that law as incorporated into the laws of the United Kingdom.
What is the legal justification for our use of Personal Data?
Summary:
Data protection law seeks to ensure that the way Personal Data is used is fair. To comply with the law, we need to tell you the legal justification we rely on for using your Personal Data. The legal justification depends on the purpose for using your Personal Data, but it will usually be considered to be in our legitimate interests or involve your consent.
In detail:
We may be required to obtain Personal Data from you to comply with applicable legal requirements, and certain Personal Data will be needed to enable us to fulfil the terms of our contract with you (or your client), or in preparation of entering into a contract with you (or your client). We will inform you of this at the time that we are obtaining the Personal Data from you. In these circumstances, if you do not provide the relevant Personal Data to us, we will not be able to provide our products or services to you. If you would like further information, please contact us using the details below (see section below ‘Who to contact about your Personal Data?’).
Sensitive Special Categories of Personal Data
For more sensitive special categories of Personal Data we will rely on either:
• your consent; or
• one or more of the following justifications (however other legal justifications may be available):
◦ the use is necessary for the establishment, exercise, or defence of legal claims, or whenever courts are acting in their judicial capacity (for example, when a court issues a court order requiring the processing of Personal Data); or
◦ the use is necessary for the purposes of preventive or occupational medicine, medical diagnosis or the provision of health or social care or treatment.
These more sensitive special categories of Personal Data include Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning an individual’s sex life or sexual orientation.
Additional legal justifications may also be available in the country in which you are based, and we may also rely on these justifications from time to time.
Processing of Personal Information relating to criminal convictions and offences is subject to the requirements of applicable law.
Where we rely on our legitimate business interests or the legitimate interests of a third party to justify the purposes for using your Personal Data, those legitimate interests will be set out in a supplemental privacy notice (which is tailored to our relationship with you (or your client) where this is useful to provide you with a full picture of how we collect and use Personal Data), but in any event our legitimate interests will be:
• pursuit of our commercial activities and objectives, or those of a third party (for example, by carrying out direct marketing);
• compliance with applicable legal and regulatory obligations, and any guidelines, standards, and codes of conduct (for example, by carrying out background checks or otherwise preventing, detecting or investigating fraud or money laundering);
• improvement and development of our business operations and service offering, or those of a third party;
• protection of our business, shareholders, employees, and customers, or those of a third party (for example, ensuring IT network and information security, enforcing claims, including debt collection); and
• analysing competition in the market for our services (for example, by carrying out research, including market research).
We need to collect, use and disclose Personal Data in connection with matters of important public interest, for instance when complying with our obligations under anti-money laundering and terrorist financing laws and regulations, and other laws and regulations aimed at preventing financial crime. In these cases, the legal justification for our use of Personal Data is that the use is necessary for matters of public interest. Additional justifications may also apply depending on the circumstances.
3. WHAT METHODS OF DATA COLLECTION DO WE USE
| Method of data collection examples | Description |
|---|---|
| Supplemental Personal Information from other sources | We, and our service providers, can supplement the Personal Information we collect with information obtained from other sources (for example, publicly available information from online social media services and other information resources, third-party commercial information sources, and information from our group companies and business partners). We will use any such supplemental information in accordance with applicable law (including obtaining your consent where required). |
| Through your internet browser or electronic device | Certain information is collected by most websites or automatically through your electronic device, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, electronic device manufacturer and model, language, time of the visit, pages visited, and the name and version of the Settld Services (such as the App) you are using. We use this information to ensure that the Settld Services function properly. |
| Through your use of an App | When you download and use an App, we and our service providers can track and collect App usage data, such as the date and time the App on your electronic device accesses our servers and what information and files have been downloaded to the App based on your device number. |
| Using cookies and online tracking | We can use cookies and other online tracking tools (with your consent where required by applicable law). Cookies are pieces of information stored directly on the device you are using. Cookies allow us to recognize your device and to collect information such as internet browser type, time spent using Settld Services, pages visited, language preferences and relevant country website. We can use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Settld Services. In addition, we can use the information to gather statistical information about the usage of the Settld Services in order to understand how they are used, continually improve their design and functionality, and assist us with resolving questions about them. Cookies further allow us to present to you the advertisements or offers that are most likely to appeal to you. We can also use cookies to track your responses to our advertisements and we can use cookies or other files to track your use of other websites.You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products. We do not respond to browser do not track signals at this time.Third parties can collect information about your use of Settld Services and your use of other websites or online services. For more detailed information about the cookies we use on our UK Site, see section ‘What cookies are used on our website?’ |
| Using pixel tags, web beacons, clear GIFs or other similar technologies | We can use pixel tags, web beacons, clear GIFs and other similar technologies with your consent (where required by applicable law).These can be used in connection with some Settld Services and HTML-formatted email messages to, among other things, track the actions of users of Settld Services and email recipients, measure the success of our marketing campaigns and compile statistics about usage of Settld Services and response rates. We can use interest-based advertising service providers to customize, target, serve and report on advertisements served across the web and mobile applications, based on information relating to our offline interactions with you, our online interactions with you (on any of your devices) and information received from third parties. To do this, these service providers can use cookies, pixel tags and other technologies to collect information about your and other users’ use of the Settld Services and third-party sites and mobile applications. They can also use these technologies along with information they collect about your online use, to recognise you across the devices you use, such as a mobile phone and a laptop. Our service providers can also match personal information we provide to them with your IP address and serve Settld advertisements to you across the web, based on your IP address. If you would like to opt out of having your information used for these purposes, visit the self-regulatory program opt out pages at www.aboutads.info/choices/ or www.networkadvertising.org/managing/opt_out.asp to opt out in desktop and mobile web browsers on the particular device from which you access the opt-out options. Download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile applications. |
| Physical location | Subject to applicable law (and your consent where required by applicable law), we can collect the physical location of your electronic device by, for example, using satellite, mobile/cell phone tower or Wi-Fi signals. We can use your device’s physical location to provide you with personalized location-based services and content. Subject to your marketing preferences and applicable law, we can also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you will be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content. In addition, we can obtain the precise geolocation of your device when you use our mobile applications for Kind Call Services. In connection with providing the Kind Call Services, we can share your device’s precise geolocation information with our clients and other entities with whom we work. You may opt-out of our collection and sharing of precise geolocation information by deleting the mobile application from your device, by disallowing the mobile application to access location services through the permission system used by your device’s operating system, or by following any additional opt-out instructions provided in the privacy notice available within the mobile application. In some circumstances, physical location information will become your Personal Information if you are identifiable in relation to the physical location information. In such cases, the physical location information will be handled as Personal Information as described in the earlier sections of this Privacy Policy. |
| Using information provided by you | Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you. |
| By aggregating information | We can group information together so that it does not link to a specific individual, i.e., aggregate, and use that information (for example, we can aggregate information to calculate the percentage of our users who have a particular telephone area code). |
4. WHAT DO WE USE PERSONAL INFORMATION FOR
Summary:
We use Personal Data for different purposes depending on our relationship with you. The main purposes are to:
• Provide Settld Services and make related assessments and decisions (automated and non-automated)
• Manage your account changes
• Communicate with you
• Obtain feedback and manage complaints
• Detect, investigate, and prevent crime
• Manage, develop, and improve our business, products, and services (including using data analysis)
• Comply with applicable laws and regulatory obligations
• Advertise and market our services.
In detail:
We use Personal Data to carry out our business activities. The purposes for which we use Personal Data will differ based on our relationship, including the type of communications between us and the services we provide. Personal Data will be used for different purposes if you are or a deceased person is an account holder of accounts you wish us to change, an appointed representative, or another individual with whom we have a relationship.
The main purposes for which we use Personal Data are to:
• Communicate with you and other individuals.
• Make assessments and decisions (automated and non-automated, including by profiling individuals) about the provision and terms of our services.
• Provide products and services
which we offer, including obtaining date of death account balance, requesting account closure or amendment, and general administration.
• Improve the quality of our products and services, provide staff training and maintain information security
(for example, for this purpose we can record or monitor phone calls).
• Prevent, detect, and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
• Carry out research and data analysis, including analysis of our customer base and other individuals whose Personal Data we collect, complete market research, including customer satisfaction surveys, and assess the risks faced by our business, in accordance with applicable law (including obtaining consent where required).
• Provide marketing information
in accordance with preferences you have told us about (marketing information may be about products and services offered by our third-party partners subject to your expressed preferences). We will carry out marketing activities in accordance with your preferences by using email, SMS and other text messaging, post, or
telephone.
• Personalise your experience when you use Settld Services by presenting information tailored to you.
• Manage our business operations and IT infrastructure, in line with our internal policies and procedures, including those relating to finance and accounting; billing and collections; IT systems operation; data and website hosting; data analytics; business continuity; records management; document and print
management; and auditing.
• Manage complaints, feedback and queries, and handle requests for data access or correction, or the exercise of other rights relating to Personal Information.
• Comply with applicable laws and regulatory obligations
(including laws and regulations outside your country of residence), for example, laws and regulations relating to anti-money laundering, sanctions and anti-terrorism; comply with legal process and court orders; and respond to requests from public and government authorities (including those outside your country of residence).
• Establish, enforce and defend legal rights
to protect our business operations, and those of our group companies or business partners, and secure our rights, privacy, safety or property, and that of our group companies or business partners, you, or other individuals or third parties; to enforce our terms and conditions; and pursue available remedies and limit our damages.
Use of Personal Data to detect, investigate and prevent fraud
Summary:
We can use Personal Data, in particular Personal Information, to detect, investigate and prevent fraud, and this includes sharing Personal Data, including Personal Information, with fraud prevention agencies and databases, and law enforcement agencies.
In detail:
We are committed to detecting and preventing fraud, and other financial crime. We take this commitment very seriously and use Personal Data in several ways for this purpose.
For example, if relevant to our relationship with you we will (where permitted by applicable law):
• Submit Personal Information and Personal Data (including details of any accounts we make changes to) so that they appear on registers of persons for whom we have acted and or utilities, banks and other persons we are authorised to deal with on your behalf or on behalf of a deceased or other person; and
• Share your Personal Data, including your Personal Information with fraud prevention agencies databases and law enforcement agencies.
For further details, please see the section below ‘With whom is Personal Data shared?’ or please contact us using the details provided below (see section below ‘Who to contact about your Personal Data?’).
Who is Personal Data shared with?
Summary:
Personal Data, including Personal Information, may be shared, as applicable, between Settld and other third parties, including:
• Utilities, financial organisations, entertainment, subscription and other home-related or digital (“Service Providers)”
• Recipients of social media sharing activities and social media companies
• Government authorities
• Third parties involved in legal proceedings.
Settld is responsible for looking after the Personal Data we collect, hold and use.
In detail:
Our contractual relationship is with the person who opens an account with us but anyone accessing our website or using our Services is subject to our Privacy Policy. Depending on the circumstances this could include individuals for whom changes in account details are carried out and who accept or are deemed to have accepted our Privacy Policy and other terms of use.
We will need to share your Personal Data (or that of other persons you supply to us or put in contact with us) with third parties in order to carry out our services (see section below ‘Who is Personal Information and Personal Data shared with?’). Those third parties will assume responsibilities under data protection law for looking after the Personal Information that they receive from us.
In detail:
In connection with the purposes described above (see section above How do we use Personal Data?), we sometimes need to share your Personal Data with third parties (this can involve third parties disclosing Personal Data to us and us disclosing Personal Data to them) as shown in the table below.
| Type of Third-party examples | Description |
|---|---|
| Service Providers | External third party service providers, such as Utilities, financial organisations, entertainment, subscription and other home-related or digital “Service Providers”; licenses and professional memberships, medical and security professionals, accountants, actuaries, auditors, financial advisors, experts, lawyers and other professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing and market research, and data analysis service providers; banks and financial institutions that service your accounts or those of our client; paper and records management providers; and other third party vendors and outsourced service providers that assist us in carrying out our Services. |
| Social media companies and recipients of your social media sharing activity | Where you have friends and other connections associated with your social media account, other website users and your social media account provider can receive your Personal Information in connection with your social sharing activity (for example, if you connect a social media account provided by another social media service provider to your Settld Services account or log into your Settld Services account from another social media account). If you connect your Settld Services account and your other social media account you authorize us to share information with the provider of your other social media account and you understand that the use of the Personal Data we share will be governed by the other service provider’s privacy policy. If you do not want your Personal Data shared with other users or with your other social media account provider, please do not connect your other social media account with your Settld Services account and do not participate in social sharing while using Settld Services. |
| Government authorities and third parties involved in legal proceedings | We can also share Personal Data with: (a) government or other public authorities (including, but not limited to: the Department of Work and Pensions for benefits; DVLA; NHS; courts, regulatory bodies, law enforcement agencies, tax authorities and criminal investigations agencies); and (b) third party participants in legal proceedings and their accountants, auditors, lawyers, and other advisors and representatives, as we believe to be necessary or appropriate. |
| Other third parties | We can share Personal Data with payees; emergency providers (fire, police and medical emergency services); retailers; medical networks, organisations and providers; travel carriers; credit bureaus; credit reporting agencies; other people involved in making changes to your accounts or those of your client; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganisation, merger, sale, joint venture, transfer or other transaction relating to all or any portion of our business, assets, companies or stock (i.e., company shares). |
Who is responsible for third party services accessed via Settld Services?
Summary:
We are not responsible for the privacy, information, or other practices of any third parties, including any third party operating any site or service to which the Settld Services link.
In detail:
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which Settld Services link. The inclusion of a link on Settld Services does not imply endorsement of the linked site or service by us or by our group companies.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the information security practices) of other organizations, such as Facebook®, Twitter®, Apple®, Google®, Microsoft®, RIM/Blackberry® or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or electronic device manufacturer, including any Personal Information you disclose to other organizations through or in connection with Settld Services.
6. HOW LONG IS THE PERSONAL INFORMATION KEPT FOR AND HOW IS IT KEPT SECURE
How do we keep Personal Information secure?
Summary:
Information security is extremely important to us. We put in place technical and physical security measures to keep Personal Data safe and secure. If, despite our efforts, you believe that Personal Data is no longer secure, please tell us so that we can resolve any security issue.
In detail:
Settld uses technical, physical, legal and organisational measures, which comply with data protection and other laws to keep Personal Information and Personal Data secure.
As most of the Personal Data we hold is stored electronically we have implemented appropriate IT security measures to ensure this Personal Data is kept secure. For example, we may use anti-virus protection systems, firewalls, and data encryption technologies. We have procedures in place at our premises to keep any hard copy records physically secure. We also train our staff regularly on data protection and information security.
When Settld engages a third party (including our service providers) to collect or otherwise process Personal Data on our behalf, the third party will be selected carefully and required to use appropriate security measures to protect the confidentiality and security of Personal Information.
Unfortunately, no data transmission over the Internet or electronic data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have sent to us has been compromised), please immediately notify us (see section below ‘Who to contact about your Personal Data?’).
How long do we keep Personal Data for?
Summary:
We will keep your Personal Information and Personal Data only as long as necessary for the purposes for which we collected it and to comply with applicable law.
Depending on our relationship with you, or your client, we will keep your Personal Information for a number of years after our relationship ends.
In detail:
We will keep Personal Data for as long as is necessary for the purposes for which we collect it. The precise period will depend on the purpose for which we hold your information. In addition, as a regulated financial services institution, there are laws and regulations that apply to us which set minimum periods for retention of Personal Information. We will provide you with further information if appropriate to give you a full picture of how we collect and use your Personal Information.
For example:
• Where we hold Personal Data to comply with a legal or regulatory obligation, we will keep the information for at least as long as is required to comply with that obligation.
• Where we hold Personal Data in order to provide a product or service (such as ensuring that probate is completed and all accounts are ratified), we will keep the information for at least as long as we provide the product or service, and for a number of years after the end of our relationship, provided, however, that in the case of sensitive Personal Information, such period of time will not exceed 15 years.
The number of years varies depending on the nature of the product or service provided. Among other reasons, we retain the information in order to respond to any queries or concerns that may be raised at a later date with respect to the provision of the Kind Call Services. Typically, the retention period is 6 years.
For further information about the period of time for which we retain your Personal Data, please contact us using the details below (see section below ‘Who to contact about your Personal Information?’).
7. WHERE IS THE PERSONAL INFORMATION STORED AND SENT
Where do we process Personal Information?
Summary:
We only process Personal Data nationally, within the UK (England, Wales, Scotland, and Northern Ireland).
In detail:
In processing Personal Data, we will take steps to ensure that such Personal Data is adequately protected in accordance with the requirements of data protection and other laws. With regards to Personal Information this typically involves the use of data processing and storage agreements in the form approved by the European Commission and permitted under Article 46 of the EU General Data Protection Regulation (GDPR) (the relevant data protection law).
For further information and to request details of the safeguards in place, please contact us using the details below (see section below ‘Who to contact about your Personal Data?’).
8. IS THE PERSONAL INFORMATION USED TO MAKE AUTOMATED DECISIONS ABOUT YOU OR TO PROFILE YOU
Are automated decisions made using Personal Data?
Summary:
Sometimes we use automated decision-making tools (i.e. where a person is not involved in the decision).
We typically use these tools when making straightforward decisions about accounts that you or your client has asked to make changes on.
You can request a manual review of the accuracy of an automated decision if you are unhappy with it.
In detail:
Sometimes, as part of our business operations, decisions about you or your client’s accounts are taken using automated computer software and systems. These decisions do not involve human input, and the software and systems apply pre-defined logic programming and criteria to decide and assess how we deal with you in connection with the provision of services.
We provide you with more information in relation to any automated decision processes before or at the time that we intend to make decisions in this way. You have the right in certain circumstances not to be subject to a decision, which is based solely on automated processing. Please see the section below ‘What are your Personal Information rights?’ below for further details of this right.
9. WHAT ARE YOUR RIGHTS
Summary:
Individuals in the European Economic Area (EEA) and in the United Kingdom have a number of rights in connection with their Personal Information. These rights only apply in certain circumstances and are subject to certain exemptions. These rights include a right to request a copy of the Personal Data we hold about you.
If you wish to exercise these rights, please contact us using the details below (see section below ‘Who to contact about your Personal Information?‘)
In detail:
The following is a summary of the data protection rights available to individuals in the European Economic Area (EEA), and currently in the United Kingdom, in connection with their Personal Data. These rights may only apply in certain circumstances and are subject to certain legal exemptions. If you wish to exercise your rights, please contact us using the details below (see section below ‘Who to contact about your Personal Data?’).
| Description | When is this right applicable? |
|---|---|
| Right of access to Personal Data You have the right to receive a copy of the Personal Data we hold about you and information about how we use it. |
This right is applicable at all times when we hold your Personal Data (subject to certain exemptions). |
| Right to rectification of Personal Data You have the right to ask us to correct Personal Information we hold about you where it is incorrect or incomplete. |
This right is applicable at all times when we hold your Personal Data (subject to certain exemptions). |
| Right to erasure of Personal Data This right is sometimes referred to as ‘the right to be forgotten’. This right entitles you to request that your Personal Data be deleted or removed from our systems and records. However, this right only applies in certain circumstances. |
Examples of when this right applies to Personal Data we hold include (subject to certain exemptions): • When we no longer need the Personal Data for the purpose we collected it; • If you withdraw consent to our use of your information and no other legal justification supports our continued use of your information; • If you object to the way we use your information and we have no overriding grounds to continue using it; • If we have used your Personal Data unlawfully; and • If the Personal Data needs to be erased for compliance with law. |
| Right to restrict processing of Personal Data You have the right to request that we suspend our use of your Personal Data. However, this right only applies in certain circumstances. Where we suspend our use of your Personal Data we will still be permitted to store your Personal Data, but any other use of this information while our use is suspended will require your consent, subject to certain exemptions. |
You can exercise this right if: • You think that the Personal Data we hold about you is not accurate, but this only applies for a period of time that allows us to consider if your Personal Data is in fact inaccurate; • The processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of its use instead; • We no longer need the Personal Data for the purposes we have used it to date, but the Personal Data is required by you in connection with legal claims; or • You have objected to our processing of the Personal Data and we are considering whether our reasons for processing override your objection. |
| Right to data portability This right allows you to obtain your Personal Data in a format that enables you to transfer that Personal Data to another organisation. However, this right only applies in certain circumstances. You have the right to have your Personal Data transferred by us directly to the other organisation, if this is technically feasible. |
This right will only apply: • To Personal Data you provided to us; • Where we have justified our use of your Personal Data based on: – Your consent; or – The fulfilment by us of a contract with you; and • If our use of your Personal Data is by electronic means. |
| Right to object to processing of Personal Data You have the right to object to our use of your Personal Data in certain circumstances. |
You can object to our use of your Personal Data where you have grounds relating to your particular situation and the legal justification we rely on for using your Personal Data is our (or a third party’s) legitimate interests. However, we can continue to use your Personal Data, despite your objection, where there are compelling legitimate grounds to do so or we need to use your Personal Data in connection with any legal claims. |
| Right to object to direct marketing This right is different where it relates to direct marketing and you can read about how to exercise your right to opt-out of receiving any direct marketing in the ‘How can you tell us about your marketing preferences?’ section of this Privacy Policy. |
You can also object to the use of your Personal Data for direct marketing purposes at any time (including if we are carrying out profiling related to direct marketing). |
| Rights relating to automated decision making and profiling You have the right not to be subject to a decision, which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. However, this right only applies in certain circumstances. |
This right is not applicable if: • We need to make the automated decision in order to enter into or fulfil a contract with you; • We are authorised by law to take the automated decision; or • You have provided your explicit consent to the decision being taken in this way using your Personal Data. |
| Right to withdraw consent to processing of Personal Data Where we have relied upon your consent to process your Personal Data, you have the right to withdraw that consent. |
This right only applies where we process Personal Data based upon your consent. |
| Right to complain to the relevant data protection authority If you think that we have processed your Personal Data in a manner that is not in accordance with data protection law, you can make a complaint to the data protection regulator. If you live or work in an EEA member state, you may complain to the regulator in that state. |
This right applies at any time. |
| Right to provide instructions regarding the management of your Personal Data after your death (only where such right applies under applicable law) You may have the right to inform us of instructions on how we manage the Personal Data we hold about you after your death. |
This right is applicable at all times when we hold your Personal Data (only where such right applies under applicable law). |
10. WHAT COOKIES ARE USED ON OUR WEBSITE
What cookies are used on our website?
Summary:
Cookies are pieces of information stored directly on the device you are using. We use a number of cookies and tracking technologies on our website. Among other things, cookies help us to understand user behaviour, make our website work better and target online advertising.
In detail:
You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept all the cookies on the Site, you may experience some inconvenience in your use of the Site and some online products. In addition to the cookies mentioned above, cookies can also be placed on your electronic device when you open emails we send to you. We use these emails to track the effectiveness of our advertising.
How we use cookies
We use cookies for a number of different purposes. Some cookies are necessary for technical reasons; some enable a personalized experience for both visitors and registered users; and some allow the display of advertising from selected third party networks. Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the “like” or “follow” button on a post, for example).
Many of the cookies we use are only set if you are a registered Settld.care user (so you don’t have to log in every time, for example), while others are set whenever you visit one of our websites, irrespective of whether you have an account.
For more information on the choices you have about the cookies we use, please see the Controlling Cookies section below.
Where we place cookies
We set cookies in a number of different locations across our services. These include:
• On our websites (settld.care, *.firm.settld.care, etc.).
• In the emails we send.
Types of Cookie
The table below explains the types of cookies we use on our websites and why we use them.
| Category of cookies | Why we use these cookies |
|---|---|
| Strictly Necessary | These cookies are essential for websites on our services to perform their basic functions. These include those required to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual “carts” on sites that have an ecommerce functionality. |
| Functionality | These cookies are used to store preferences set by users such as account name, language, and location. |
| Security | We use these cookies to help identify and prevent potential security risks. |
| Analytics and Performance | Performance cookies collect information on how users interact with our websites, including what pages are visited most, as well as other analytical data. We use these details to improve how our websites function and to understand how users interact with them. |
| Advertising | These cookies are used to display relevant advertising to visitors who use our services or visit websites we host or provide, as well as to understand and report on the efficacy of ads served on our websites. They track details such as the number of unique visitors, the number of times particular ads have been displayed, and the number of clicks the ads have received. They are also used to build user profiles, including showing you ads based on products you’ve viewed or acts you have taken on our (and other) websites. These are set by settld.care and trusted third party networks, and are generally persistent in nature. |
| Third Party / Embedded Content | Sites hosted on Settld.care make use of different third party applications and services to enhance the experience of website visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons), or embedded content from Youtube and Vimeo. As a result, cookies may be set by these third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies. |
Examples
Below are examples of the cookies set by Settld.care, with explanations of their purpose. Some of these cookies are set across our whole network. Please note that this is not an exhaustive list, but rather aims to be representative. Information about cookies that may be set by third parties, such as our partners, is below.
Third-party
| Cookie | Purpose |
|---|---|
| intercom-id-[app_id] | These cookies allow this interaction with settld.care via Intercom by remembering who you are and providing access to previous conversations you’ve had through the Messenger. |
| intercom-session-[app_id] | These cookies allow this interaction with settld.care via Intercom by remembering who you are and providing access to previous conversations you’ve had through the Messenger. |
Analytics and Performance
| Cookie | Purpose |
|---|---|
| utma / utmb / utmc / utmt / utmz / g.a / gat / gid | Google Analytics. Gathers information that helps us understand how users interact with our websites, which allows us to create a better experience for our visitors. Our users may also implement Google Analytics on their own websites. |
Controlling Cookies
Visitors may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide for ways to control cookie behavior such as the length of time they are stored – either through built-in functionality or by utilizing third party plugins. If you disable cookies, please be aware that some of the features of our service may not function correctly.
To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites:
On a mobile device, you may also be to adjust your settings to limit tracking.
For example, you can opt out of Google Analytics by installing Google’s opt-out browser add-on, or from Hotjar by using the Do Not Track header.
Consent for Advertising Cookies on Our Sites
You may see a “cookie banner” on our websites and dashboards. If you are visiting one of our sites from the EU, then we do not set, or allow our ad partners to set, cookies that are used to show you targeted ads before you click to accept. When you consent in this manner, we and our advertising
partners may set advertising cookies on the site you are visiting and on our other websites, dashboards, and services, which we use to show you advertisements about our various Automattic products. We’ll display the banner to you periodically, just in case you change your mind.
Consent and Choices for Advertisements on Our Users’ Sites Through Our Ads Program
You may see a “cookie banner” on our users’ websites, particularly if you are in the European Union. If so, then our ad program does not set, or allow our ad partners to set, cookies that are used to show you targeted ads before you accept. When you consent in this manner, we and our
advertising partners may set third party advertising cookies on our network in order to show you personalized ads. We’ll display the banner to you periodically, just in case you change your mind.
We set a cookie to help us understand how visitors engage with websites that participate in our ad program. Visitors may opt out of our use of this information by visiting this link (the opt-out will be processed immediately with no confirmation step). When you opt out, we replace the unique value for that cookie with an opt-out value. The opt-out works across all websites in our ads program. If you have opted out by accident, or wish to opt back in, you may do so by visiting this link. Please note that this option is browser specific, and so if you use a different device or browser or clear your cookies, then you will need to repeat the process.
11. DO WE RECORD CALLS AND MONITOR EMAIL COMMUNICATIONS WITH US
Summary:
To protect you, our business and third parties we can record calls and monitor communications between us.
In detail:
We can record telephone calls with you so that we can:
• Improve the standard of service that we provide by providing our staff with feedback and training;
• Address queries, concerns or complaints;
• Prevent and detect crime, including fraud and money laundering, and analyse and manage other commercial risks; and
• Comply with our legal and regulatory obligations.
In addition, we monitor electronic communications between us (for example, emails) to protect you, our business and IT infrastructure, and third parties including by:
• Identifying and dealing with inappropriate communications; and
• Looking for and removing any viruses, or other malware, and resolving any other information security issues.
12. HOW CAN YOU TELL US ABOUT YOUR MARKETING PREFERENCES
Summary:
You can change your marketing preferences at any time. If you would like to stop receiving marketing information from us, please contact us by email: contact@settld.care
In detail:
We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you.
To tell us your marketing preferences, and to change your preferences if required, you can contact us by email: contact@settld.care
In addition, you can also opt-out of receiving marketing communications as follows:
• Receiving email messages and text messages from us: If you no longer want to receive marketing emails or text messages from Settld , you can opt-out of receiving these marketing-related messages by clicking on the link to “unsubscribe” provided in each email message, following the stop instructions in a text message, or by contacting us using the address above.
• Receiving telephone communications and electronic mail from us: If you no longer want to receive marketing via telephone communications or electronic mail from Settld , you may opt-out of receiving these marketing communications by contacting us using the addresses above. You may also be able to contact a “Do not call” registry in your country to opt-out on a general basis from receiving marketing communications by telephone, although we may still contact you if you are listed on such a register if you have given your consent.
• Sharing of your Personal Information with our group companies for their marketing purposes: With your consent we can share your Personal Information with our group companies for their own marketing purposes. If you change your mind, you may opt-out of this sharing by contacting us using the address above.
• Sharing of your Personal Information with selected third-party partners for their marketing purposes: If you have provided your consent, we can share your Personal Information with our third party partners for their own marketing purposes. If you change your mind, you may opt-out of this sharing by contacting us using the address above.
We aim to comply with your opt-out requests within a reasonable time period and in any event within any period prescribed by law. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e. to those to whom we have already provided your Personal Information as of the date on which we respond to your opt-out request).
Please also note that if you do opt-out of receiving marketing communications from us, we can still send you other important service and administration communications relating to the services, which we provide to you, and you cannot opt-out from these service and administration communications.
13. WHO CAN YOU COMPLAIN ABOUT THE USE OF YOUR PERSONAL INFORMATION
We try to ensure that we deliver the best levels of customer service but if you are not happy you should make contact so that we can investigate your concerns. If you have any questions or concerns about the way your Personal Data is used by us, you can contact us by email or post.
| Post: | Email: | Telephone: |
| Compliance Department, Kind Call Ltd T/A Settld, 9th Floor | support@settld.co.uk | 0333 111 1111 |
| Post: | Email: | Telephone: |
| Floor, Building 5 Exchange Quay, Manchester, United Kingdom, M5 3EF | care@settld.co.uk | 1111 |
You can also contact our Data Protection Officer at legal@settld.care
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body that regulates the handling of personal data in the United Kingdom. You can do this online through the ICO’s website at www.ico.org.uk., by telephone on 0303 123 1113, or by writing to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.
14. WHEN WAS THIS PRIVACY POLICY LAST UPDATED
Summary:
This Privacy Policy was last updated on 01/10/2024. We may review this policy and make changes from time to time.
In detail:
We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business activities, legal requirements, and the manner in which we process Personal Data. We will place updates on this website and where appropriate we will give reasonable notice of any changes.