Melissa UK Privacy Notice
19 March 2024
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Who We Are
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Information We Collect About You
- Identity Data includes first name, last name, username or similar identifier, title.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Support Data includes the content of your communications with us when you contact customer support.
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How We Collect Your Information
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services
- request marketing to be sent to you
- request help solving technical issues
- give us feedback or contact us
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
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How We Use Your Personal Information
- Where we need to perform obligations under a contract that we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- When you have given your consent. For example, you may give your consent to us to send third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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Who We Share Your Information With
- share aggregated, anonymised or other de-identified data with advertisers, advertising networks and social networks that require the data to select and serve relevant adverts to you and others. We will also use aggregate information to help advertisers reach the kind of audience they want to target
- make use of the personal information we have collected from you to help our advertisers display their advertisements to a target audience and to present our promotional messages to you. This means you will be presented with advertisements that are more likely to be relevant to you
- share your personal data with and access information from analytics and search engine providers that assist us in the improvement and optimisation of the website and app and for better personalisation of content and advertising
- if we discuss selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality
- if we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you
- if we're required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police
- if we are defending a legal claim your information may be transferred as required in connection with defending such claim
- if there is an emergency which requires us to share your data to protect the health and safety of our website's or app's users or the general public
International Transfers
How We Protect Your Information
Data Retention
Your Rights
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is also called the “right to know and obtain a copy.”
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. This is also called the “right to correct.”
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. This is also called the “right to delete.”
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Does Melissa Do Credit Checks?
We provide identity verification services to financial institutions and other businesses to help them comply with Know Your Customer (KYC) regulations. These checks are a crucial part of the fraud-prevention process when an individual is opening an account involving financial transactions.
When a business requests a KYC check, they collect information and consent from you and pass it on to us to perform the check. For privacy reasons, we do not store or retain any information obtained for this purpose.
Key Points to Understand:
- Purpose of Identity Checks: Our identity checks are not credit checks. They are conducted to verify the accuracy of the information provided to us, such as your name, address, and date of birth, to ensure the legitimacy of your identity.
- Use of Credit Bureau: In some cases, we may share your information with a credit bureau, like Equifax, solely to confirm your identity. This process might result in a record that appears on your credit report, typically listed as "Search - Other" or “ID.” This is not a credit check and does not impact your credit score.
- Privacy and Data Handling: We do not retain any information used for these identity checks. Once the verification is completed and the result is returned to our customer, we immediately destroy the entire record.
By clarifying this process, we hope to address any concerns and provide transparency about our services. If you have any further questions or require more information, please feel free to contact us.
How To Contact Us Or Make A Complaint
Glossary
Your personal information is collected by Melissa Data Ltd., registered in England under company number 09536931. We respect your privacy and are committed to protecting your personal information. This notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. Historic versions can be obtained by contacting us.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your information changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Children
While our website is designed for a general audience, we will not knowingly collect any data from children under the age of 13 or sell products to children. If you are under the age of 18, you are not permitted to register an account, use or submit your data to the website.
If we discover that we have collected any personal information from a child under the age of 18, we will suspend the associated account and remove that information from our database as soon as possible.
If you believe we might have any personal information from or about a person under the age of 18, please contact us using our Consumer Privacy Request Form.
Personal data, or personal information, 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 which may include:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 information which will be used in accordance with this privacy notice.
If you fail to provide personal information
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
To find out more about the types of lawful basis that we will rely on to process your personal data refer to the GLOSSARY in Section 12, below.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Third-party marketing - we will not share your information with any third parties for the purposes of direct marketing.
Opting out - you can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Cookies - you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose - we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
There are certain circumstances where we transfer your personal information to other parties. For example we will:
We share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other service providers include advertising agencies, IT suppliers, database providers, backup and disaster recovery specialists, and email providers.
Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including information about consumers like you, will only be provided in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this privacy notice.
Your personal information may be transferred to other third party organisations in certain scenarios:
Your personal data may also be shared with third parties if it is made anonymous and aggregated. In such circumstances the information will cease to be personal data.
We share your personal data our suppliers and service providers. This will involve transferring your data outside the United Kingdom (UK). Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Where we share your personal data with organisations located in third countries that are not covered by an adequacy decision, we rely on standard contractual clauses (SCCs), with the UK Addendum where required, as our mechanism to safeguard the transfer.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal information for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data.
Sometimes we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us using our Consumer Privacy Request Form.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions about this privacy notice or our privacy practices, please contact us using our Consumer Privacy Request Form. You may also contact our UK office at +44 (0)20 7718 0070.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.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.
Lawful Basis
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. Consent means processing your data where you have freely given, specific, informed and unambiguous indication of your wishes.