Choice Freedom Privacy Policy

This Website is brought to you by Choice Member Benefits Limited ("Choice Freedom"). Choice Freedom respects the privacy of your personally identifiable information. To better protect your privacy, we provide this notice explaining our online information practices and the choices available to you concerning the way that we use the information collected online at this Website and if you purchase goods or services through the Website. Please read this carefully.


Information Collection and Use - General Terms


We collect your personally identifiable information when you register or sign up to receive products and/or services at the Website. The types of personally identifiable information that we collect at this Website, during registration and when you make a purchase include, without limitation your name, postal address, e-mail address, telephone numbers and billing account information. In addition, we may request information about your use of, or interest in, the types of products and services offered by the third-party advertisers with whom we have partnered to offer you the products and services available at this Website. Any personal information that you submit at the Website remains your property. However, by submitting that information to us, you agree that we may use your personal information for:

a) effecting a purchase from Choice Freedom that you make at the Website;

b) setting up your account to pay for purchases from the Website (which requires you to enter into a credit card agreement with Choice Freedom)

c) transferring your personal information to a third party to effect a purchase from a third party advertiser at the Website;

d) marketing purposes such as sharing your information with third party advertisers, partners, and associates;

e) providing promotional offers to you by means of telemarketing, text messaging, direct mail marketing, pop-ups, pop-unders and/or online banner advertising. Your email address will only be shared with our mailing partner, All Inbox, LLC, who will send relevant, daily financial offers on our behalf.

f) tracking compliance with our Terms and Conditions;

g) validation, suppression, content improvement and feedback purposes;

h) providing you with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Website.


You specifically authorise, and provide your express consent to receive, telemarketing calls from us including auto-dialed calls, on your landline telephone and/or your mobile phone (if your number was provided). You understand that wireless carrier standard network rates may apply to any calls to your mobile phone. In addition, you agree that by submitting your personal information at the Website, notwithstanding that your telephone number may be registered with the Telephone Preference Service, we may contact you via telemarketing unless you advise us you do not want to receive calls by following our opt-out instructions


If you do not want us to use your data for marketing purposes, please follow the opt-out instructions. By filling out or submitting a registration form or partial registration form you are consenting to receive offers from us via email, telemarketing, post and or SMS text message wireless or other mobile offering to your mobile phone. You understand that your wireless carriers´┐Ż standard network charges and rates apply to these messages. For SMS text messages, you may opt out of receiving future marketing messages by replying 'stop', 'end', or 'quit' to the SMS text message you have received and we will remove your personal information from our marketing list within 10 days of receiving such request.


In connection with the products and services available for purchase at the Website, we will collect your payment account information. We will use your payment account information to bill you for your purchases and we may share your payment account information with third parties for the sole purpose of effecting any transactions that you enter into at the Website. In addition, by submitting your payment account information to us, you authorise Choice Freedom to periodically verify that your payment account continues to be a valid and active one by charging and, thereafter immediately crediting, a small sum to your account. Such verification may be conducted through a third party service provider and, in that case, Choice Freedom will share your specific payment account information with this third party for verification purposes. Apart from the foregoing uses, Choice Freedom reserves the right to share with other third parties the fact that we have payment account information on file for specific individuals, but we will not share the actual payment account information with other third parties without the applicable individual's prior informed consent.


We may share with third party advertisers certain Website usage information of individuals that have received targeted promotional campaigns for the purpose of formatting future campaigns and upgrading visitor information used in reporting statistics. For this purpose, we may track some of the pages that you visit on our Website through the use of pixel tags (also called clear gifs). By submitting information at and/or registering at this Website, you agree to allow us to share such Website usage information with third parties.


We may also disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Choice Freedom or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use any credit agreement entered into by you to purchase goods from this Website and other agreements; or to protect the rights, property or safety of Choice Freedom, our customers or others. This includes exchanging information with other companies and organisations for the purpose of fraud protection and credit risk reduction.


Information Collection and Use - Credit Agreement Terms


If you purchase goods from the Website, we will enter into a credit agreement with you to finance the purchase of such goods. In addition to the collection and use of personal information set out above, the following terms shall apply to personal information collected in relation to the credit agreement:

(a) We may carry out searches on you at the credit reference agency, Callcredit Information Group Limited ("the CRA"). In considering your application we will use your personal information from your application and from the CRA to make decisions about you. The CRA may add details of our searches and your application to their records about you. This information will be made available to other organisations that perform searches on you at the CRA. Information held about you at the CRA may already be linked to records relating to one or more of your partners. This is called an "association" and for the purpose of your application and the credit agreement, you may be treated as financially linked and assessed with reference to any associated records.

(b) We may also add to your records at the CRA:

  • Details of any credit agreement entered into with us;
  • The payments that you make under such credit agreements;
  • Any default or failure by you to keep the terms of such credit agreements; and
  • Any failure by you to tell us about a change of address where a payment is overdue.

(c) Your records held by the CRA will be shared with other organisations that make searches and may be used by us and those other organisations to:

  • Help make decisions about credit and credit related services (e.g. insurance) for you and your household;
  • Trace debtors, recover debt, prevent money laundering and fraud and to manage our accounts;
  • For other purposes for which you have given your agreement.

(d) For the purposes set out at (c) we or those other organisations may make further searches. These searches will be added to your records but will not be shared with others.

(e) We and the CRA may also use the information held about you for statistical analysis about credit, insurance and fraud and to conduct market research.

(f) If you breach any term of this agreement we may pass details of the breach to any associate of ours or to other companies in our group who will use this information to make decisions about other agreements that you may have with them.

The CRA may be contacted at 0845 366 0071.


Choice Freedom as an Agent


Please be advised that in certain circumstances, Choice Freedom acts as a limited agent for the actual seller of the products and/or services available for purchase at or through the Website. In these circumstances: 1) you will be redirected to the applicable seller's website after you have completed the application page; 2) Choice Freedom will collect and send your personal information to the respective seller in connection with completing your purchase from the seller; and 3) your purchase will subject you to the seller's privacy policy.


Third Party Links


Choice Freedom does not endorse, nor is Choice Freedom responsible for the accuracy of, the privacy policies and/or terms and conditions of each of the third party advertisers that may advertise at this Website. The entities that advertise and/or place banner ads at this Website including, but not limited to, these third party advertisers, are independent third parties and are not affiliated with Choice Freedom.


Your Choices


You may request that we do not share your information with third parties by visiting: Choice Freedom Opt Out and filling out the appropriate information. Please note that changing your preferences regarding the receipt of marketing communications from us will not prevent other companies with which we already have shared your information, including third party advertisers, from continuing to provide you with offers. When contacted by these companies, you should notify them directly of your choices regarding their use and sharing of your information. In addition, please note that if you subsequently sign up for another one of our product or service offerings, you will need to reconfirm any information sharing preferences that you have previously changed. You have the right to access the personal information we hold about you. Please contact us at memberservices@choicefreedomcard.co.uk or write to us at Riverside House, 44 Wedgewood Street, Fairford Leys, Aylesbury HP19 7HL if you require a copy of the information we hold about you. Your request will be subject to a £10 fee to meet our costs in providing you with details of the information we hold about you.


Non-Personally Identifiable Information


We may collect certain non-personally identifiable information about you when you visit many of the pages of this Website. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Firefox, Netscape, Internet Explorer, etc.), your IP address, the type of operating system that you use (e.g., Mac OS, Windows, Linux, etc.) and the domain name of your Internet service provider (e.g., BT, Sky, Plusnet, etc.). We use the non-personally identifiable information that we collect to improve the design and content of our Website and to enable us to personalise your Internet experience. We also may use this information in the aggregate to analyse Website usage, as well as to offer you products and services. We also reserve the right to use aggregate or group data about our visitors for lawful purposes. Aggregate or group data is data that describes the demographics, usage and/or characteristics of our visitors as a group. By visiting and/or supplying your personal information at this Website, you agree to allow us to provide such aggregate data to third parties. We also may use "cookies" to enhance your experience in using our Website. Cookies are text files that we place in your computer's browser to store your preferences. We use cookies to understand Website usage, to personalise your experience, and to improve the content and offerings on our Website.


Minors


We do not knowingly collect information from minors under the age of 18. No information should be submitted to, or posted at, this Website by individuals under 18 years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.


Where we store your Personal Information


The personal information that we collect from you may be transferred to, and stored at, a destination in the United States of America ("USA"). It may also be processed by staff operating in the USA who work for us or one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy policy.


Security


Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use industry standard security measures to safeguard against unauthorised access to information that we collect online. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share this password with anyone.


Acceptance


By using the Website and/or agreeing to receive information via e-mail from Choice Freedom, you agree to this Privacy Policy. We reserve the right, in our sole discretion, to change, modify, add and/or remove portions of this Privacy Policy at any time. All Privacy Policy changes will take effect immediately upon their posting on the Website. Please check this page periodically for any changes. Your continued use of the Website and/or acceptance of our e-mail communications following the posting of changes to this Privacy Policy will constitute your acceptance of any and all changes.


Contact Us


If you have any questions regarding this statement, or would like more information on our privacy practices, please contact our Member Services department during normal business hours. To opt-out of any future messages please visit Choice Freedom Opt Out.


Dated: April, 24 2014

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