Let’s Connect IT Solutions Limited (hereafter referred to as Let’s Connect) is a subsidiary company of Personal Group Holdings plc. Let’s Connect takes the privacy of your information very seriously. This policy explains how the companies in the group collect information and what we use the information about you for.
The information we hold is collected and managed by the following companies –
- Let’s Connect – collect your information through our benefits website (www.hapibenefits.com) and main business website (www.lets-connect.co.uk);
- Personal Management Solutions Limited – collect your information provided through our websites;
All of the companies has the same registered office which is John Ormond House, 899 Silbury Boulevard, Central Milton Keynes MK9 3XL. The Data Protection Officer for the companies can be contacted on firstname.lastname@example.org or by calling 0333 400 0844.
Personal Management Solutions Limited oversees all of the data management within the Personal Group to ensure that we comply with this policy and the data protection rules.
The personal information we collect and hold
Employee data: Let’s Connect is sometimes provided with employee’s personal data from its employer clients, which it has been authorised to use by them. We will use this information as we are instructed which may include providing details to you via the employee benefits sites we host and confirming you are authorised to use these. Where this personal data is passed to Let’s Connect, we processes it on behalf of your employer and its use is limited to what is permitted by your employer. We will act in accordance with the permission to use the data that your employer holds.
The data provided by employers may include email, first name, surname, payroll, postal address and date of birth. Where we provide information to you for your employer we will hold that information.
Website data: When you register with one of our internet sites (the Site) you will provide your personal information and agree to our terms and conditions which incorporate this policy. The data will be processed, stored and used by Let’s Connect in accordance with this policy.
When you first register on the Site, we ask for some basic personal data. This will include your date of birth and postcode when receiving an email invite, those registering on the site will also need to provide their payroll number. The Site will also ask you to provide an email address, as well as other personal information. You may provide additional information when you choose to make a purchase from or accessing a service on the Site including payment details. Other personal information about you is optional for you to provide during registration and this is clearly shown.
Face to face sales data: When you meet with a member of the sales team at a roadshow or other event they may collect personal information from you, at which point you agree that they may access the information held by Let’s Connect which either you or your employer has provided. The information will include your name, date of birth, details of your employment and of any products you have with us.
How we use and disclosure personal information
We and third parties may use your personal data provided to the Site or via face to face sales for purposes which may include:
- providing you with a personalised service, which may be subject to the requirements your employer selects or whether you have opted to receive marketing – you will agree to this where it concerns the benefits your employer requests or is subject to your consent if it concerns marketing
- to create your account and to identify you, we may share your information with your employer to verify you are entitled to an account – you agree to this as part of your agreement to use the Site
- sharing information on your use of employee benefits with your employer so they can consider how their programme is working – you agree to this as part of your agreement to use the Site
- providing information to your employer to confirm you are eligible to use the Site – you agree to this as part of your agreement to use the Site
- checks with your employer to ensure that you and other users are entitled to access their benefits scheme – you agree to this as part of your agreement to use the Site
- processing your orders, registrations and enquiries – you agree to this when making an order or as part of your agreement to use the Site
- providing information on the scheduling of launch visits – you agree to this as part of your agreement to use the Site
- providing you with information about promotions and products and services we offer – if you have consented to receive such information and not opted out – see below
- sharing your Data with third party organisations who offer products or services which we feel may be of interest to you (if you agree to receive such information) – this is only done with your consent when you use the Site to move to an offer you want more details of
- providing data to third party organisations who provide services which you choose to receive – you agree to this as part of your agreement to use the Site.
- displaying user feedback (if the individual agrees to the information being displayed) – if you consent to this and have not withdrawn your consent.
We will use your data in providing any insurance product you purchase from us. We may share this information with third parties where necessary to provide the service. This information is all used so we can carry out or obligations or rights under these contracts with you. We use your personal information when providing insurance to:
- administer your product, including ensuring that premiums are paid
- to consider any claims or complaints you may make
- to pay any claims
- deal with any queries or meet any requirements of our regulators – this is a legal obligation on us
Where we process your data, it is subject to our strict internal policy requirements as well as the Data Protection regulations.
How long will we hold your personal information
We will hold the personal information we use to meet the requirements of our agreements with you for the period of those agreements and any further period afterwards that we need for regulatory or other legal reasons (such as to defend any claims). This will usually mean that we will hold information for seven years after an agreement ends. We will remove any personal information we do not need when we no longer need it.
Where we have personal information which you have consented for us to use we will hold it for the period the consent remains in force and any other period we need for regulatory or other legal reasons. You may remove your consent at any time.
We will delete any information about you we no longer need. Please see below in relation to your rights to have data erased, rectified or for you to access it and for you to object to any processing or to transfer it.
You have a number of rights in relation to your personal information. These are –
- The right to confirm if we are using data about you and to access details about what we are using and how;
- The right to lodge a complaint with the Information Commissioners Office;
- The right to have us rectify any inaccurate data corrected or to have data which is incomplete for the purpose we hold it completed;
- The right to be forgotten. Which is the right to ask us to delete information about you and if it is appropriate to do so we will do so;
- The right to restrict what we do with data in specific circumstances, including where the accuracy of the data is contested, processing is unlawful but you do not want us to erase the data or if we only need the data to meet legal requirements;
- The right to receive the data we hold about you in a format you can use to transfer the data electronically elsewhere.
You are also able to withdraw any consent you have provided for use to use your data at any time. This is opting out and the process is set out below.
You can opt out by unsubscribing from the benefits communication you receive or alternatively within your account on the Site under “Me”
Your privacy and data protection is very important to us and we comply with all aspects of the Data Protection legislation and ensure that any third parties we engage do so. You can find out more about your rights to data from the Information Commissioners Office.
Some data processing may occur in other parts of the European Union (“EU”) or outside of the EU. Wherever data is processed your rights under the Data Protection Regulations will be met and we will ensure that any agreement to process your data ensures this and give you rights in the unlikely event of any security breach.
When you visit the Sites we may store some information (commonly known as a “cookie”) on your computer. Cookies are pieces of information that a Site transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords are not stored in cookies.
A cookie helps you get the best out of the Site and helps us to provide you with a more customised service.
Cookies expire once you close your browser.
Please note, that if you set your browser to reject cookies you may not be able to use certain aspects of the Sites.
Cookies on the www.hapibenefits.com do the following:
- Track your transactions and the way you navigate the Site. When you make a purchase it is cookies that give us the information to track your transactions and which retailers you have used. It also tells us which third party sites you’ve clicked through to.
- Keep you logged in to your account for a period of time.
- Allow us to comply with your choices about the display of information in your account.
- Remember the options you select (such as favourite merchants).
Permit integration with social media sites (such as the ability to “like” hapi on Twitter).
Provide you with recommended offers, based on your use of hapi and the transactions you enter into through it.
Credit/Debit Card Information
When you register a card on the Site it will be recorded to use with purchases on the Site.
The card data will be transferred to, and stored at, secure third party destinations to provide those services which involve processing card information on our behalf, to ensure successful transactions. All data is stored in an encrypted format and can only be accessed when you place an order using your required details which links a match.
We advise you never to enter your bank card, account number or password into an email or after following a link from an email. We will never ask you to do this in an email.
Anonymous Site Statistics
We may automatically collect non-personal information such as the type of internet browsers being used to view our Site. You will not be identified from this information and it is only used to assist us in providing an effective service on this Site.
Partners Privacy (If ‘Partner Invite’ is made available)
All the above information applies to the partners site, with the following exception: No partners data is given to us by the employees employer. At point of invite, the employee will enter their partner’s title, name, email address and confirmation they live at the same address. If the partner chooses to decline the invite, all data will be automatically removed from our system.
If you have any enquiry relating to your personal information, you can do so by sending an e-mail to us at email@example.com
(Please note that because of the insecure nature of emails we cannot accept any responsibility for data lost or intercepted in transit.)
Or write to us at:
The Data Protection Officer (Let’s Connect IT Solutions Limited)
John Ormond House
899 Silbury Boulevard
Central Milton Keynes
Telephone 0333 400 0844
Fax 01908 201711
Personal Group are based in Milton Keynes and processes all data in accordance with UK data protection laws.