The Plan Group Limited t/as Yellow Jersey (also referred to as “we”, “us”, or “our”) are a registered company in England (Company no. 04108942). Our registered address is Prospero, 73 London Road, Redhill, Surrey, England, RH1 1LQ.
The purpose of this policy
This policy is designed to help you understand what kind of information we collect in connection with our products and services and how we will process and use this information. In the course of providing you with products and services we will collect and process information that is commonly known as personal data.
This policy describes how we collect, use, share, retain and safeguard personal data.
This policy sets out your individual rights; we explain these later in the policy but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
What is personal data?
Personal data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, their gender and contact details.
Personal data may contain information which is known as special categories of personal data. This may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to or sexual orientation. Personal data may also contain data relating to criminal convictions and offences.
For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.
How do we collect your data?
- Directly from you through our website using online forms
- Social media platforms
- Our website and blog
When do we collect your data?
- We will gather your data when you register on our website.
- We may also collect personal information about you when you use our websites and blog, complete a survey, enter one of our competitions or use our social channels.
What data will we gather?
We will only gather data that is necessary for us to provide our services to you. This data will include both personal and special category data. The following are examples of the data we will gather:
- Personal data, contact information.
- Browsing insights, marketing preferences.
How is your personal information handled by us?
The protection of your information is important to us and we therefore have security measures in place which are appropriate to the nature of the information we hold and to the harm that might result from a breach of security.
- We do not hold more information about you than is required for the purposes for which it is being processed
- We endeavour to ensure that any information about you is accurate and kept up to date
- We do not keep your information for longer than is necessary or as required by law
- We process your information in accordance with your rights under the relevant Data Protection Laws
We will share your personal data within our group of companies including affiliates and subsidiaries.
We also share personal data with authorised third parties.
If you contact us by telephone, a selection of telephone calls will be recorded for training and quality purposes.
Our lawful bases for processing your information
Below we list the lawful bases under which we may process your personal data
Consent: when you give us your clear consent that we can process your data or a specific purpose.
Contract: processing is necessary for us to execute a contract
Legal obligation: processing is necessary for us to comply with the law
Vital interests: processing is necessary to protect someone’s life.
Public task: processing necessary to perform a task in the public interest
Legitimate interests: processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate.
In the table below we summarise how we collect data, for what purpose, and our legal bases for processing it:
|Purpose||Type of information||How the data is collected||Legal basis for processing|
|To carry out our business of providing independent cycling holiday reviews||Your basic details (e.g. name, email address)||Online forms||Our legitimate interests
|To improve our offer and services||Online customer behaviour insight (e.g. time and general location when you visited our website)
Devices you used to interact with our services (e.g. phone model or PC screen size)
Pages of our websites or blogs you have visited, links clicked, emails opened
Time spent on a page or form
Information you share while leaving your feedback or posting on our social channels
|Cookies placed on our websites: google analytics (sessions and browsing insights), hotjar (activity on the website), google adwords (remarketing)
|Our legitimate interests|
|Competitions and prize giveaways
|Your basic details (e.g. name, email address)
Basic social media profile: twitter handle and name, Facebook profile name
Your name, address and phone number in order to send you a prize and to contact you
Other ad hoc data, typically if we ask a question (e.g. “what is your holiday?”)
Social media platforms
Our website and blog
|Our legitimate interests
|Marketing and Offers||Your basic details (e.g. name, email address)||Online forms
Social media platforms
Our website and blog
|Our legitimate interests
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
- The right to be informed about the personal data being processed;
- The right of access to your personal data;
- The right to object to the processing of your personal data;
- The right to restrict the processing of your personal data;
- The right to rectification of your personal data;
- The right to erasure of your personal data;
- The right to data portability (to receive an electronic copy of your personal data);
- Rights relating to automated decision making including profiling.
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.
You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health related matters.
The flow of data within the insurance sector is complex and we ask you to keep this in mind when exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations to help satisfy your request this may impact on timescales.
If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact our data privacy representative Nick Cole by e-mailing firstname.lastname@example.org or by writing to Plan Group Ltd, Prospero, 73 London Road, Redhill, RH1 1LQ .
We will retain your personal data at the end of any contractual agreement for a period of 7 years. Where you have contacted us for details of our services and products, we will retain your personal data for 18 months. Where you make a complaint we will retain the data for 7years. Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.
The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis (profiling) and product development and marketing purposes.
Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.
We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our business and authorised third parties.
If you are dissatisfied with any aspect of the way in which we process your personal data please contact our data privacy representative Nick Cole. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office(ICO). The ICO may be contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.
How to contact us
If you have any questions regarding this policy, the use of your data and your Individual Rights please contact us at Yellow Jersey, Prospero, 73 London Road, Redhill, RH1 1LQ or by e-mailing email@example.com or by telephoning 03330030046.