This is where you can find all you need to know about how we use your personal information (referred to here as "your Information") and also about your rights and how to exercise them.
We are TransferMyBills.com Limited and we are the "controller" of your Information, which means we are answerable to you and to the ICO* for how we collect, use, share, store and protect it.
However, we want to put you in control – after all, it's your Information – so below we've described what we do with your Information, as well as your rights and how to contact us.
* Information Commissioner’s Office, the UK’s data protection regulator.
Our Privacy Promise
So here is our Privacy Promise to you:
- We will be open and honest with you about our use of your Information.
- We'll only use and share it for the purposes described below
- We will explain below why it's lawful for us to use your Information for each purpose
- We won't collect more Information than we need for any of these purposes
- We'll work with you to make sure your Information is accurate and kept up to date
- We'll tell you how long we are legally permitted or required to keep it
- We will protect your Information and respond quickly to any concerns you may have
Your Information will only be processed in the UK or EU, where it is protected by the same laws as in the UK. If this changes, we will put in place legally binding measures to ensure that any processing of your Information complies with UK law and we will provide details in this Privacy Notice.
To provide the TransferMyBills service
We collect and use your Information when you register an account with us:
- You provide your name and contact details and your new address and moving date
- You nominate the service providers you wish us to notify of your move and you provide any further Information they will need to update their records
- You provide instructions, such as "transfer my gas bill" or "change my address" for us to pass on to these service providers.
We use and share your Information with your nominated service providers to deliver the TransferMyBills service and to check and confirm to you that your instructions have been followed.
Our use of this Information is lawful because it is necessary to fulfil our contract with you.
We keep this Information for seven years in case you or we need it to help resolve a dispute.
To protect you and our other customers
We request proof of your identity for your own protection and as an important security measure so, as part of your initial registration, we will offer you the ability to provide certain information, such as driving licence and bank account details. These details are transmitted directly to our ID verification partner GB Group plc.
They perform the verification checks and send us the result, which we record on our system simply as "Pass" or "Fail". We do not keep copies of the details you provided or any other Information relating to proving your identity.
Our collection and use of this Information to verify your identity is lawful because it is necessary to fulfil our contract with you.
To manage and improve our service
Feedback & Testimonials
We may occasionally ask you for feedback or you may send us unsolicited feedback about our service. If we quote your comments in our marketing and advertising, we will not identify you but we may publish, for example, your first and last initials and the town in which you live so as to demonstrate that the quote is genuine.
Statistical data for Utilities & Service Providers
We provide statistical and analytical information to service providers to help them run their businesses and improve their services to customers. This data is created by anonymising your Information and combining it with information from other customers. Neither you nor anyone else can be identified from this statistical data so, in legal terms, it is no longer personal information and the Information Rights described below will not apply. We take steps to ensure that the process can't be reversed and of course we continue to protect it.
Anonymising and aggregating your Information to help produce statistical data is lawful because we have a legitimate interest in developing new and improved information-based services. As required by law, we have performed a Legitimate Interests Assessment ("LIA") of our interests to ensure that they are not overridden by your rights and we have found that this de-identification and aggregation of data and our subsequent use of it poses no risk to your rights. A copy of the LIA is available on request.
To operate and improve our website
We use a third party, FullStory, to record activity on our website for the purpose of helping our support team to resolve problems you may encounter using the TransferMyBills online service and to make our site easier to use. However, the data received and recorded by FullStory is anonymous as they cannot access any of the information you enter (name, addresses, service providers etc.)
You can see full details in our Cookie Notice.
Marketing and Advertising
We will use your contact details and details of the TransferMyBills services you have used to send you information about our other services that we think may be of interest to you.
With your permission, we'll let your service providers know that you’re happy to receive special offers and details of discounts and promotions from them. You can sign up to receive email, SMS or phone notifications and promotions by clicking on the "My Preferences" link in your account, and you can always ask us to stop at any time.
Suppliers pay to advertise and post special offers and promotions for TransferMyBills customers on our website where they hope to reach and retain their existing customers. If you have registered with TransferMyBills and notified us of your suppliers, we will use this information, where applicable, to ensure that your suppliers adverts and offers appear when you log into our site. As we do not use tracking cookies, this function only works on our website when you are logged in. We don’t provide any of your Information to your suppliers – or any other suppliers – but we do send them statistical reports, e.g. numbers of customers who visited our site and will have seen their advertisement.
Facebook custom audience pixel
TransferMyBills places ads on Facebook. The Facebook pixel is a piece of code, owned and placed on our website by Facebook, to ensure that our ads are only seen by Facebook users who have visited our website in the past six months. We don’t receive any information about you from Facebook. For more info about the pixel, see Facebook's Data Policy or Terms of Service.
Sharing your Information
We engage a number of third parties to provide IT services. They have access to the data, which may include your Information, on our systems and on systems they operate for us but only where necessary to maintain and support those systems. Your Information is also encrypted so, in many cases, even those third parties will not be able to see it in identifiable form.
We would disclose your Information if required to do so by law, for example, under a court order.
In the event that TransferMyBills is acquired by another company, your Information will be passed to them so they can continue to provide the TransferMyBills service and to process your Information in accordance with the applicable Terms and Conditions and this Privacy Notice.
Your Information Rights & how to exercise them
Your personal information is just that – it's personal and it's yours – so we will make sure it's easy for you to take control of it.
These are legal rights that the ICO will help you to enforce if we slip up.
- Right of access to your Information – we will provide you with the Information we hold
- Right to have inaccurate or out of date Information corrected
- Right to unsubscribe from marketing messages and emails
- Right not to be profiled for marketing purposes – we don't do this anyway
- Right to prevent processing of your Information
- Right to have your Information deleted (also known as "Right to be Forgotten")
- Right to transfer your Information to another provider (also known as "Right of Portability")
- Where the lawful basis for our processing is your consent, you may withdraw it at any time
- Right to make a complaint to the ICO (see "Lodging a complaint" below).
If you tell us you want to exercise your rights, we'll confirm that we have received your request and let you know if we need anything else from you, then we will respond as quickly as possible and, in any case, within a month.
Lodging a complaint
If we fail to respond within a month when you send us a request to exercise any of these rights, or if you are unhappy about the way we or any of our partners are handling your Personal Information, you can lodge a complaint by contacting firstname.lastname@example.org.
If you are not happy with our response or handling of your complaint, you have the right to report your concern to the Information Commissioner’s Office, whose contact details can be found on their website at: www.ico.org.uk/global/contact-us
If you have any questions or concerns about our handling of your Information, you can contact us at email@example.com.
Our registered address is Transfermybills.com Ltd, 288 Jeans Way, Dunstable LU5 4PT.
ICO Registration number: ZA557826