Privacy policy
1. Introduction
1.1 Important information and who we are
Life Moment’s mission is to help people play life better. Central to this mission is our pledge to be transparent with you about the data we collect from you and how it is used.
We are committed to ensuring that the confidentiality and security of your information is protected. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
The Site is owned and operated by Life Moments Limited (“us”, “our”, “we”). We are committed to protecting the privacy of users of the Site.
At Life Moments Limited we are committed to protecting and respecting your privacy and personal data in compliance with the law and guidelines of the EU General Data Protection Regulation (“GDPR”).
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include customers and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
Please use the Glossary at the bottom of this policy to understand the meaning of some of the terms used in this Privacy Policy.
1.2 Who is Your Data Controller and Data Protection Officer
Life Moments Limited is your Data Controller and is responsible for your Personal Data.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the DPO using the details set out below:
Full name: Paul Carse
Email address: paul@life-moments.co.uk
Postal address: 21 Chatsworth Avenue, Wimbledon, London, SW20 8JZ, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.otg.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.
1.3 Processing Data on behalf of a Controller and Processors’ responsibility to you
In discharging the responsibilities of the Data Controller, we have Processors who deal with your data on behalf of the Data Controller. Therefore, the responsibilities described below may be assigned to an individual or maybe taken to apply to the organisation as a whole. The Data Processor has the following responsibilities:
Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases).
Ensure that persons authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data
Obtain the prior specific or general written authorisation of the Controller before engaging another Processor
Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller
Maintain a record of all categories of processing activities carried out on behalf of a Controller
Cooperate, on request, with the supervisory authority in the performance of its tasks
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process them except on instructions from the Controller
Notify the Controller without undue delay after becoming aware of a Personal Data Breach
Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority
Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain his or her expert knowledge
2. Legal basis for data collection
2.1 Types of Data / Privacy Policy Scope
Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
Profile/Identity Data: This is data relating to your first name, last name, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
Communications Data: This is your preferences in receiving marketing information and other information from us.
Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
Customer Support Data: This includes feedback and survey responses.
Usage Data: information about how you use our website, products and services.
Personal Financial Data: This includes annual salary and current savings
We also collect, use and share Aggregated Data such as “30% of our customers are currently saving £x.” 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. 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.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.2 The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow the collection and processing of Personal Data. The main avenues we rely on are:
Consent: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt-in’ to a service.
Contractual Obligations: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
Legal Compliance: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
Legitimate Interest: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address so that we know where to deliver something to, or your name so that we have a record of who to contact moving forward.
3. How we use your personal data
3.1 Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.
