Privacy Policy

Title: Lucid Group Privacy Policy

Last updated May 2018.

How we use your personal information

Your information will be held by Lucid Group. This privacy notice is to let you know how we promise to protect your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice also tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

  • To keep your data safe and private.
  • Not to sell your data.
  • To give you ways to manage and review your marketing choices at any time.

Personal information and the law
This section tells you who we are, what your personal information is, and how we get it. It explains how the law protects you by controlling what is allowed to happen to it.

  1. Who we are
  2. How the law protects you
  3. Groups of personal information
  4. Where we collect personal information from
  5. How long we keep your personal information
  6. If you choose not to give personal information
  7. Cookies

The control you have
This section covers how to complain or withdraw your consent. It also tells you how you can get a copy of your personal information, or ask for it to be changed or removed.

  1. How to complain
  2. How to withdraw your consent
  3. Letting us know if your personal information is incorrect
  4. How to get a copy of your personal information
  5. What if you want us to stop using your personal information?

How personal information is used
This tells you who we share personal information with. It explains what it’s used for in marketing or for legitimate interests.

  1. Who we share your personal information with
  2. How we work out what marketing you receive
  3. How we use your information to make automated decisions
  4. Sending data outside of the EEA 

 

Personal information and the law

Who we are

This section gives you the legal name of the company who holds your personal information – known as the ‘legal entity’ – and tells you how you can get in touch with us.

The legal entities which comprise Lucid Group are:-

Lucid issuer Services Limited

Lucid Agency & Trustee Services Limited

Lucid Trustee Services Limited

Lucid Agency Services Limited

Lucid Nominees Limited

 

Contacting us about data privacy

Please use these details to contact us about any of the topics set out in this Privacy notice.

If you have any questions, or want more details about how we use your personal information, you can ask us via our dedicated email address: privacy@lucid-is.com

Or you can call us on +44 (0)20 7704 0880

Lines are open 0900 until 1700 London time, Monday to Friday.
Calls may be monitored or recorded.

These are our main contact details. Some sections of this notice have special contact details that you can use instead.

If you are not satisfied with our response, you can contact our Group Data Compliance Officer.

Name: Eusebio Echevarria
Email: compliance@lucid-is.com

How the law protects you

This section sets out the legal reasons we rely on, for each of the ways we may use your personal information.

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Lucid Group. The law says we must have one or more of these reasons

  • To fulfil a contract we have with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest, or
  • When you consent to it.

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

  • For reasons of substantial public interest, or
  • To establish, exercise or defend legal claims.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

 

 

What we use your personal information for

 

Our reasons

 

Our legitimate interests

 

Serving you as a customer
• To manage our relationship with you or your business
• To develop and carry out marketing activities
• To study how our customers use products and services from us
• To communicate with you about our products and services
• To develop and manage our brands, products and services
• Your consent
• Fulfilling contracts
• Our legitimate interests
• Our legal duty
• Keeping our records up to date, working out which of our products and services may interest you and telling you about them
• Developing products and services, and what we charge for them.
• Defining types of customers for new products or services
• Seeking your consent when we need it to contact you
• Being efficient about how we fulfil our legal and contractual duties
Business improvement
• To test new products
• To manage how we work with other companies that provide services to us and our customers
• To develop new ways to meet our customers needs and to grow our business
• Fulfilling contracts
• Our legitimate interests
• Our legal duty
• Developing products and services, and what we charge for them
• Defining types of customers for new products or services
• Being efficient about how we fulfil our legal and contractual duties
 

 

Managing our operations

• To deliver  our products and services
• To make and manage customer payments
• To manage fees
• To collect and recover money that is owed to us
• Fulfilling contracts
• Our legitimate interests
• Our legal duty
• Being efficient about how we fulfil our legal and contractual duties
• Complying with rules and guidance from regulators
 

 

Managing security, risk and crime prevention

• To detect, investigate, report, and seek to prevent crime
• To manage risk for us and our customers
• To obey laws and regulations that apply to us
• To respond to complaints and seek to resolve them
• Fulfilling contracts
• Our legitimate interests
• Our legal duty
• Developing and improving how we deal with crime, as well as doing our legal duties in this respect
• Complying with rules and guidance from regulators
• Being efficient about how we fulfil our legal and contractual duties
 

Business management

• To run our business in an efficient and proper way. This includes managing our financial position, business capability, adding and testing systems and processes, managing communications, corporate governance, and audit • Our legitimate interests
• Our legal duty
• Complying with rules and guidance from regulators
• Being efficient about how we fulfil our legal and contractual duties
• To exercise our rights set out in agreements or contracts • Fulfilling contracts
For processing special categories of personal data – if in future applicable
• Substantial public interest • Using criminal records data to help prevent, detect, and prosecute unlawful acts and fraudulent behaviour.
• Responding to regulatory requirements • Showing whether we have assessed your situation in the right way.
• Passing information to the relevant regulator as needed to allow investigation into whether we have acted in the right way.
• Legal claims • Using any special categories of data as needed to establish, exercise or defend legal claims
• Consent • Telling you that we need your consent to process special categories of personal data, when that is what we rely on for doing so.

 

 

 

 

 

Groups of Personal Information

This explains what all the different types of personal information mean, that are covered by data protection law.

We use many different kinds of personal information. They are grouped together like this. The groups are all listed here so that you can see what we may know about you, even if we simply get it from seeing which shops you buy things in. We don’t use all this data in the same way. Some of it is useful for marketing, or for providing services to you but some of it is private and sensitive and we treat it accordingly.

Type of personal information Description
Contact Your name, email address phone number, and how to contact you
Transactional Details about payments to and from your accounts with us
Contractual Details about the products or services we provide to you
Data we get about where you are. This may come from your mobile phone, or the place where you connect a computer to the internet.
Technical Details on the devices and technology you use
Communications What we learn about you from letters and emails you write to us, and conversations between us
Usage Data Other data about how you use our products and services
Documentary Data Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, driving licence, or account certificates.
Special categories of data The law and other regulations treat some types of personal information as special. We do not collect or use this data:

·       Racial or ethnic origin

·       Religious, political or philosophical beliefs

·       Trade union membership

·       Genetic and bio-metric data

·       Health data

·       Lifestyle information, including data related to sex life or sexual orientation

·       Criminal records of convictions and offences

·       Allegations of criminal offences

You can read how we may use special types of data in the table ‘How the law protects you’

Consents Any permissions, consents, or preferences that you give us. This includes things like if you want us to contact you.

 

Where we collect personal information from

This section lists all the places where we get data that counts as part of your personal information.

We may collect personal information about you (or your business) from other Lucid Group companies and any of these sources:

Data you give to us:

  • When you apply for our products and services or enter into contractual agreements
  • When you talk to us on the phone or in physical business meetings, including recorded calls and notes we make
  • When you use our websites, or platform services
  • In emails and letters

 

Data we collect when you use our services. 

  • This covers two things: details about how and where you access our services, and account activity such as document downloads or data reads.
  • Payment and transaction data.
    This includes the amount, frequency, type, location, origin and recipients
  • Profile and usage data.
    This includes the security details you create and use to connect to our services. It also includes your settings and marketing choices. We also gather data from the devices you use (such as computers and mobile phones) to connect to our website and platform services.
    We also use cookies and other internet tracking software to collect data while you are using our websites or platform services. You can find out more about this in our Cookies policy.

Data from outside organisations:

  • Companies that introduce you to us (such as a Dealer Manager or Legal team)
  • Social networks (for instance, when you click on one of our LinkedIn ads)
  • Public information sources such as the Electoral Register or Companies House

 

How long we keep your personal information

This section explains how long we may keep your information for and why

We will keep your personal information for as long as you are a customer of Lucid Group.

We may keep your data for up to 10 years after you stop being a customer. The reasons we may do this are:

  • To respond to a question or complaint, or to show whether we gave you fair treatment
  • To study customer data as part of our own internal research
  • To obey rules that apply to us about keeping records

We may also keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.

We will only use your personal information for those purposes and will make sure that your privacy is protected.

 

If you choose not to give personal information

You can choose not to give us personal information. In this section we explain the effects this may have.

We may need to collect personal information by law, or to enter into or fulfil a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from fulfilling our contract with you, or doing what we must do by law. It could mean that we cancel a product or service you have with us.

We sometimes ask for information that is useful, but not required by law or a contract. We will make this clear when we ask for it. You do not have to give us these extra details and it won’t affect the products or services you have with us.

Cookies

This section contains a link to our Cookies Policy

Cookies are small computer files that get sent down to your PC, tablet or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from, when you go there again. Cookies store information about your visits to that website, such as your choices and other details. Some of this data does not contain personal details about you or your business, but it is still protected by this Privacy notice.

To find out more about how we use cookies, please see our Cookies Policy.

 

The control you have

How to complain

This section gives details of how to contact us to make a complaint about data privacy. It also shows you where you can get in touch with the government regulator.

Please let us know if you are unhappy with how we have used your personal information. You can contact us using our dedicated email: privacy@lucid-is.com

You also have the right to complain to the regulator, and to lodge an appeal if you are not happy with the outcome of a complaint.

In the UK this is the Information Commissioner’s Office. Find out on their website how to report a concern.

 

 

How to withdraw your consent

 

This section explains what to do if you no longer want us to hold or use your personal information.

You can withdraw your consent at any time. Please contact us using our dedicated email – privacy@lucid-is.com if you want to do so.

This will only affect the way we use information when our reason for doing so is that we have your consent. See the section ‘Your Rights’ about more generally restricting use of your information.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

 

Letting us know if your personal information is incorrect

Here you can find out how to contact us if you think the information we hold for you is wrong, incomplete or out of date.

You have the right to question any information we have about you that you think is incorrect. We’ll take reasonable steps to check this for you and correct it.

If you want to do this, please contact us using our dedicated email – privacy@lucid-is.com.

Calls may be monitored or recorded.

 

How to get a copy of your personal information

This section tells you where to write to us to get a copy of your personal information, and how to ask for a digital file you can use yourself or share easily with others. You can do this online or by writing to us.

You can get a copy of all the personal information we hold about you, please contact us using our dedicated email – privacy@lucid-is.com

 

When you want to share your data with outside companies

You also have the right to get certain personal information from us as a digital file, so you can keep and use it yourself, and give it to other organisations if you choose to. If you wish, we will provide it to you in an electronic format that can be easily re-used, or you can ask us to pass it on to other organisations for you.

If you want to do this, please contact us using our dedicated email – privacy@lucid-is.com

 

Your rights

What if you want us to stop using your personal information? This section explains about your right to object and other data privacy rights you have – as well as how to contact us about them.

You can object to us keeping or using your personal information. This is known as the ‘right to object’.

You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights.

You can ask us to restrict the use of your personal information if:

 

  • It is not accurate
  • It has been used unlawfully but you don’t want us to delete it
  • It is not relevant any more, but you want us to keep it for u in legal claims
  • You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it

 

If we do restrict your information in this way, we will not use or share it in other ways while it is restricted.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact please contact us using our dedicated email – privacy@lucid-is.com

Or you can call us on +44 (0)20 7704 0880

Lines are open 0900 until 1700 London time, Monday to Friday.
Calls may be monitored or recorded 

How personal information is used

Who we share your personal information with

Here we list all the types of organisation that we may share your personal information with.

Lucid Group
We may share your personal information with other companies in the Lucid Group.

Authorities
This means official bodies that include:

  • Central and local government
  • HM Revenue & Customs, regulators and other tax authorities
  • Law enforcement and fraud prevention agencies

How we work out what marketing you receive

We use marketing to let you know about products, services and offers that you may want from us. This section tells you how we decide what marketing to show or send you. It also explains how we work out what you may be interested in.

We may use your personal information to make decisions about what products, services and offers we think you may be interested in. This is what we mean when we talk about ‘marketing’.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not conflict unfairly with your own interests.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from outside organisations we work with. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

This is called profiling for marketing purposes. You can contact us at any time and ask us to stop using your personal information this way.

If you allow it, we may show or send you marketing material online via our website or platform, or by email.

Regardless of if you consent to our email marketing, you’ll still receive information where it is related to contractual deals or platform specific information where you have registered for platform access, and other important information such as changes to your existing products and services.

We do not sell the information we have about you to outside organisations.

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can contact us to update your choices at any time.

How we use your information to make automated decisions

Here we tell you how we use automated systems to make decisions about you and your services. We also explain the rights you have to challenge decisions made this way.

We sometimes use systems to make automated decisions about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. Automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them. They are based on personal information that we have or that we are allowed to collect from others.

Here are the types of automated decision we make:

Pricing
We may decide what to charge for some products and services based on what we know, for instance we will have information based on the number of Deals previously contracted. This information may be process by our systems and help staff infer pricing and product decisions.

Tailoring products, services, offers and marketing
We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products, services and offers for different customer segments, and to manage our relationships with them. It also helps us tailor the marketing that individuals receive or are shown on our own websites and platform services.

Detecting fraud
We use your personal information to help decide if your personal or business accounts may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.

Your rights
As a person you have rights over automated decisions.

  • You can ask that we do not make our decision based on the automated systems alone.
  • You can object to an automated decision and ask that a person reviews it.

If you want to know more about these rights, please contact us.

Data transfers out of the EEA
FPAs and other organisations we share data with for these purposes may send personal information to countries outside the European Economic Area (‘EEA’). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

Sending data outside of the EEA

This section tells you about the safeguards that keep your personal information safe and private, if it is sent outside the EEA.

We will only send your data outside of the European Economic Area (‘EEA’) to:

  • Follow your instructions
  • Comply with a legal duty
  • Work with our suppliers who help us to run your accounts and services

If we do transfer your personal information outside the EEA to our suppliers, we will make sure that it is protected to the same extent as in the EEA. We’ll use one of these safeguards: