When you use our technology, website, app, portal or services we may collect personal information about you. We are committed to ensuring your privacy and have put together this Privacy Policy, so you know:
Who are we?
We can be contacted in writing at the address below or on email at support@myearnie.co.uk if you have any comments about this Privacy Policy.
We last updated this Privacy Policy on the 30th June 2022.
Ashwoods Lightfoot Limited owns and operates this website. We are a company registered in England and Wales under company number 08287918. Our registered address is Winslade Park, Manor Drive, Chudleigh, Clyst St Mary, Exeter, EX5 1FY.
What Personal Information do we collect about you?
We may collect certain information about you when you use websites within the myearnie.co.uk domain, our mobile apps or the Earnie Web Portal. The type of information we collect could be:
We collect information about you in two different categories:
How we will collect your personal information
When you use the website, mobile apps or the Earnie Portal
We may collect personal information from you when you:
When using Earnie
Information you give us directly:
Information provided by your mobile device (Earnie) allows us to:
Information our Website and the Earnie Portal collect automatically
When you visit our website or use our services, we may collect certain information automatically such as:
If you want more information about how we use cookies, you can find out more by reading our Cookies Statement.
Information we collect from other sources
For Users where their service is paid by an employer or other
We may receive information from your employer, so that we can provide you with your Earnie account invitation and allow you to sign up to our app, the Portal and our associated services.
Other Organisations
We work with a number of other organisations such as payment processing companies, internet search engines, rewards partners, marketing organisations and cookie providers who may provide us with information about you.
These organisations include:
How we use your Personal Information
Our legal basis for using your information
The law only allows us to use your personal information in certain limited circumstances:
We will most commonly process your personal information in the following situations:
What does this mean in practice?
We may use your information to:
Our Marketing
We will send you our newsletter and other offers if you sign up for an account via the web portal or Earnie app. Or you have signed up for receiving such offers as our Newsletter on our website.
If you are a registered user of Earnie, we may send you information with our special offers and will offer you the chance to sign up to receiving offers from third parties about related products.
We may use your information for market research and analysis so that we can ensure that we tailor our services to the requirements of our users.
Depending on what contact information you have given to us, we may contact you by email, mobile push notification, SMS/MMS message, or social media.
We will only do this where you have consented to receiving such information from us. You can opt out of such marketing at any time via the app or web portal account settings or by email to us at support@myearnie.co.uk
Sharing your data
Employer or other Earnie bill payer
If you are a user where your Earnie access is provided by a third party such as an employer, we will share information about you with the third party per their agreement. The type of information will depend on the services that your employer subscribes to and you will be informed of what information is shared by your employer. Your employer is the data controller for this information and further information about how they use your information can be obtained from them.
Other third parties
We have explained above that we may share your personal data with third parties in order to provide the Earnie services. If you wish to take advantage of our offers with third parties then you will be asked for your consent before, we transfer you to any other organisation’s website.
We may also share your information with:
We work with the following organisations:
Salesforce (www.salesforce.com), our CRM system which manages weekly newsletters with our customers. It also provides analytics as to how you interact with us.
Amazon Web Services (aws.amazon.com), our cloud services partner which securely stores information from our Lightfoot devices.
PayPal (www.PayPal.com), our payment processor.
Kumulos (www.kumulos.com) who provides mobile messaging and analytics.
Legal Requirements and Law Enforcement
We may also disclose your information if:
Third Party Privacy Policies
This Privacy Policy applies only to Earnie systems, and not to websites or content owned by third parties. We may provide links to other websites and content, and we suggest that you check the policies of these sites before giving them your personal information as we cannot accept responsibility.
Keeping your Personal Information
Where we store your Personal Information
We are committed to ensuring that both we and our suppliers have appropriate technical, administrative and physical procedures in place to ensure that your information is protected against loss or misuse.
We require all our suppliers who handle your personal information to have appropriate technical, administrative and physical procedures in place to ensure that your information is protected against loss or misuse. We work closely with our suppliers to make sure that this requirement is met.
If a supplier is outside of the EEA, we will ensure that they have entered into a data transfer agreement that is consistent with the requirements of applicable law and that gives the individuals enforceable rights and effective legal remedies and provides adequate levels of protection in relation to any Personal Data that is transferred.
Any card payment transactions enacted by or on behalf of Earnie (which is a product of Ashwoods Lightfoot Ltd) will be encrypted. 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.
Emails
We have procedures and security features in place to try and keep your data secure once we receive it. If you choose to send us information via email, we cannot guarantee the security of this information until it is delivered to us.
Retention of Information
We only hold your personal information for as long as necessary for the purposes for which we collected your information.
We outline below how long we retain information for and how it is deleted:
| Description of data | Retention Period | Reason for Retention Period | Method of Disposal |
|---|---|---|---|
| Contact details | Statutory or 1 year after contract end. | Contract fulfilment | Delete or anonymise data. |
| Demographic details | 1 year after contract end. | Provision of Earnie services + deletion time | Delete or anonymise data. |
| Payment details | Statutory or 1 year after contract end | Contract fulfilment | Delete or anonymise data files. |
| Transaction history | Statutory limits | Statutory requirement | Delete or anonymise data files. |
| Photographs | 1 year after contract end for product system. As agreed with the subject for any marketing. | Provision of Earnie services + deletion time. Promotion of goods and services. | Delete data files. |
| Online browsing history and statistics | 3 years | Provision of Earnie services + deletion time | Delete or anonymise data files. |
| User KPI information | 1 year after contract end. | Provision of Earnie services + deletion time. | Delete or anonymise data. |
| CRM based marketing database | 3 years after the last enquiry has been received or within 7 days of a request to unsubscribe. | Provision of information on Lightfoot news, product and services | Delete from CRM system. |
We have set these timescales in accordance with any applicable legislation and where none exists then we will keep your information for the duration of any contract that you have entered into with us and then for a period of 7 years after which time it will be deleted.
Where you have requested marketing information from us, then we will only keep this information for a maximum of up to 3 years. If you do not contact us further during this period, then your information will be deleted.
Your Rights
You have the right to access information that we hold about you. If you wish to receive a copy of the information that we hold, please contact support@myearnie.co.uk or write to us at the address above.
You can ask us at any time to change, amend or delete the information that we hold about you or ask us not to contact you with any further marketing information. You can also ask us to restrict the information that we process about you.
You can request that we change, amend, delete your information or restrict our processing by using the check boxes on the forms we use to collect your information, emailing us at support@myearnie.co.uk, or writing to us at the address at the beginning ofthis Privacy Policy.
Right to prevent automated decision making
You have a right to ask us to stop any automated decision making. If you would like to request, we stop, or you have any questions or concerns we would be happy to discuss them with you and you can contact us at support@myearnie.co.uk.
Transferring Personal Information
You have the right to request that your personal data is transferred by us to another organisation (this is called “data portability”). Please contact us at support@myearnie.co.uk with the details of what you would like us to do, and we will try our best to comply with your request. It may not be technically feasible, but we will work with you to try and find a solution.
Complaints
If you make a request to us under this Privacy Policy and you are unhappy with the response, you can ask for the request to be reviewed under our internal complaints procedure. Our internal complaints procedure allows your request to be reviewed by our ISMS team lead who will do their best to try and resolve the issue.
If you have been through the internal complaints procedure and are still not happy with the result, then you have the right to complain to the Information Commissioner’s Office. They can be contacted as follows:
Address:
Information Commissioners OfficeIf you are an international resident, you may wish to complain to the relevant country's ICO.
Changes to our Privacy Policy
The internet and data privacy best practice are both developing. We therefore reserve the right to revise this Privacy Policy at any time. If this Privacy Policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
How to contact us
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@myearnie.co.uk.