1. Background.
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
International Compensation Lawyers Limited is a fully registered UK Company. International Compensation Lawyers Limited (“We”, “Us”, “Our”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
2. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 3, below.
3. What Personal Data Do We Collect?
In order to provide you with our service and pass your details on to our mis sold Timeshare lawyers so they can contact you by phone and provide you with more information on whether you have a suitable claim for a mis-sold Timeshare. We do not knowingly, deliberately or aim to, collect personal data from children under the age of 18, either for registration or for marketing purposes. If you are 18 or over we may collect some or all of the following personal data (this may vary according to your relationship with us).
Full name
Title
Date of birth
Gender
Address
Email address
Telephone number
Information about your preferences, interests, and responses to questions (which vary but could include financial information)
Demographic information
Your IP Address
Cookies
We collect your personal data in a number of ways:
When you fill in a website form on one of our websites.
When you provide personal data on any area of our website;
When you get in touch with us by email, social media, telephone, writing, and any other means;
When you subscribe to our services to receive communications from us about products and services e.g. by a newsletter, through social media etc.
4. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. We collect for personal information in order to provide you with our service and pass your details on to one of our mis-sold timeshare clients so they can contact you by phone and provide you with more information on whether you have a suitable claim for a mis-sold timeshare. The information we hold is held securely within an encrypted database. We take the protection of this data very seriously and will only routinely share data via secure systems with relevant clients (who are named within this Privacy Policy) in the interest of clients, to establish whether a mis-sold timeshare service is suitable and then progress with a mis-sold timeshare claim service. We may, on occasion, also be legally required to share data with regulatory bodies, including the Ministry of Justice, the Financial Ombudsman Service, the Legal Ombudsman and the Information Commissioner’s Office.
Your personal data may be used for one of the following purposes under a legitimate interest or consent basis. The method of communication will be by telephone. The method of communication will be determined by the consent you have provided.
To manage your registration on our owned sites;
Determine whether any of the clients or approved partners we work with may have services, products and offers that may be of interest to you based on the preferences and permissions you have supplied to us; and
With consent, communicate your data to our trusted partners and clients. You may object to this processing at any time by contacting us on the details provided in Part 14 below.
Improve and personalise our site to you, and this could be where we may market directly to you, about other relevant offers that may be of interest to you based on your preferences;
Depending on the consents that you have provided and what personal data we hold about you, we may pass your personal data to named site sponsors or named brand partners (third parties, third party) who may contact you by telephone for direct marketing purposes.
For analysis purposes. Where this is done, the information is aggregated and wherever possible anonymised in line with the ICO’s code of practice. These products are of a marketing nature.
We may process your personal data ourselves or through third party data processors that will process data on our behalf. We ensure the data processor complies with this policy and all current data protection regulations.
Telephone data will only be released to third parties where you have given your explicit consent, at the time of registering your interest on our site (or any of our supplier websites) allowing you to fully understand what you are consenting to.
If you consent to a call from one of our sponsors or brand partners this will override the TPS.
The legitimate interests can be your interests or our interests. They can include commercial interests, individual interests or broader societal benefits but we need to be able to identify a legitimate interest; show that the processing is necessary to achieve it; and balance it against your interests, rights and freedoms.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by telephone with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you always have the opportunity to opt-out.
We only ever send personal information to 3rd parties where you have given consent to do so. To prevent fraud and to ensure data accuracy it is necessary to submit your information for verification and filtering.
This enables us to provide our services to you, and fulfil our legal obligations. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure servers that are subject to strict security requirements.
5. Do You Share My Personal Data?
We will only ever share some or all of your personal data with selected third parties that are named within this Privacy Policy. We share your personal information in order to provide you with our service and pass your details on to our named mis-sold timeshare specialist lawyers so they can contact you by phone and provide you with more information on whether you are suitable for a mis-sold timeshare reclaim service.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described in Parts 5 and 9.
6. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 14.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 14 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have, subject to terms and conditions. Please contact us using the details in Part 14 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to data portability. This means that, if you have provided personal data to us directly, we am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
7. What Are Cookies And How Do We Use Them?
Our websites use cookies to collect information. Cookies are small data files which are placed on your computer or other mobile or handheld device (such as smart ‘phones or ‘tablets’), as you browse our websites. They are used to ‘remember’ when your computer or device accesses our websites. We do not use cookies to collect or record information on users’ name, address or other contact details. The cookies stored on your computer or other device when you access our websites are set by us and other third parties. Cookies may also be set by third parties who we use for marketing. None of these third parties collect any personal data from which they would be able to identify individual customers.
The main purposes for which cookies are used are:
For technical purposes essential to effective operation of websites.
To drive marketing, particularly banner advertisements and targeted updates.
Our cookie policy can be found here and informs users what cookies are used on this site, why we use them, how to manage them, and how to disable them.
If you want to disable cookies you need to change your website browser settings to reject cookies. How to do this will depend on the browser you use. In general the site may not operate effectively if cookies are deactivated.
8. How And Where Do You Store Or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
9. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. We will keep your contact details following an enquiry to our website for a period of 6 months. After 6 months your personal information is placed in a suppression file for a further 18 months. We need to do this to ensure you do not receive any further communication from us or from any of our partners if your information has been supplied to them previously and for fraud prevention purposes.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14.
To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 day’s and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.
11. How Can You Refer A Concern To The UK Supervisory Authority In Respect Of Data We Hold About You?
We are regulated by the Information Commissioner’s Office (ICO) in respect of our obligations to protect your data. You have the right to raise a concern about our use of your data to the ICO, who will investigate this on your behalf. The ICO will only investigate complaints made within three months of your last contact with us.
You can contact the ICO through their website: https://ico.org.uk or by telephone: 0303 123 1113.
12. Copyright
You may download, print extracts and/or make copies of works on this site for your own personal and non-commercial use, providing you acknowledge Timeshare Compensation Lawyers as the source of the information and include a link to our website.
13. Changes To This Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes, although anything that will affect you will be communicated directly to you.
14. Information About International Compensation Lawyers
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the details provided below and address this for the attention of the Data Protection Officer.
International Compensation Lawyers Limited
3rd Floor – MTM
82 King Street
Manchester
M2 4WQ
