Privacy Policy
Last updated: 2nd December, 2024
COMFYRELO PRIVACY POLICY
Hello!If you are reading this, then you care about privacy – and your privacy is very important to us. The purpose of this Privacy Policy is to give you a clear explanation about how we collect and process your personal information through browsing or using our website www.comfyrelo.com (“Website”). It is important that you read this Privacy Policy, or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information. This Privacy Policy supplements our other policies and is not intended to override them. This Privacy Policy has been prepared in accordance with the Data Protection Act 2018 which implements the General Data Protection Regulation (or such UK legislation intended to replace or supersede it) (“Data Privacy Laws”). Defined terms used in the Privacy Policy have the meanings set out in the Data Privacy Laws.
If you provided personal data of other people for the purpose and fulfilment of a residential service, it is your responsibility to notify these people that their data is/was provided to ComfyRelo.
How do we collect personal data
We use different methods to collect data from and about you including through:
● Direct interactions. You may give us your Identity, Contact and Financial
● Data by filling in forms, such as requesting a quote, 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;
● create an account on our website;
● subscribe to our service or publications;
● contact us through social media;
● request marketing to be sent to you;
● enter a competition;
● promotion or survey;
● give us some feedback;
● contact us via Whatsapp;
● speak with us on the telephone and we record the call;
● make a complaint;
● Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
Identity and Contact Data from:
● companies providing commercially available data who may be based inside the EU such as TwentyCi or Facebook (based outside the EU);
● from third party portals through which you request services that we provide;
● publicly available sources such as social media sites, including Facebook, YouTube and LinkedIn (based outside the EU), Companies House, HM Land Registry and the Electoral Register (based inside the EU).
Technical Data from the following parties:
● analytics providers such as Google based outside the EU;
● advertising networks such as Google based outside the EU;
● search information providers such as Google based outside the EU;
● Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Checkout, Stripe or Adyen who may be based outside the EU.
How we use personal data
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:
● Where we need to perform the contract 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.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending 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.
Marketing
We will hold your personal data on our client management systems and use this to provide you with marketing information about similar services offered by us to those which you have engaged us to provide which we feel you might find useful from time to time. You can opt out of receiving this information at any time.
If you would like to opt-out of:
● emails, except those that relate to your booking, you can do so by clicking“Unsubscribe” on the footer on any email; or
● direct marketing, you can do so by logging into your account and clicking“Unsubscribe from marketing emails” on your profile page.
Call recording
We may record any incoming or outgoing calls handled by the ComfyRelo support team (or transferred to any other department), and any call recordings may be used as follows:
● to monitor call quality;
● to train and develop ComfyRelo staff;
● to keep a record of what is said about an event or complaint;
● to review and develop our processes to better support our users and check for any mistakes; and
● to prevent, detect and investigate any possible fraud.
If your call is being recorded, you will hear a pre-recorded message stating this before connecting to a member of the ComfyRelo support team and directing you to this Privacy Policy. The recording starts when you hear a beep and ends automatically when the call ends or when the call is transferred externally.
If you do not want your call to be recorded, please tell the person you are speaking to at any time that you wish the recording to be stopped. Call recordings are only accessed by members of staff at ComfyRelo. If you would like a copy of any call recording, you can submit a request in writing to david.ho@ComfyRelo.com.
Call recordings will be securely stored for 12 months after the call was made and will be managed in accordance with Data Privacy Laws.
Who we share your personal data with
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers (where possible) to ensure they can only use your personal information to provide services to us and to you. These will include but will not be limited to:
● If we sell any part of our business and/or integrate it with another organisation, your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their adviser.
● If this occurs, the new owners of the business will only be permitted to use your information in the same or similar way as set out in the privacy policy
● We will share personal data with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations.
● We may share an encoded version of your personal data to third parties such as Facebook and google to enable these third parties to display ComfyRelo ads when you visit their websites.
We routinely share personal data with:
● Our insurers and/or professional advisers as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defence of legal claims;
● With companies who provide us with or support our IT systems and website: We use reputable third parties to provide us with our IT systems, applications and website and support for them.
● With companies who provide marketing support services to us: We use reputable third parties to provide us with marketing support services.
● With our suppliers, to the extent necessary in order to provide services to us;
● With our payment services providers, only to the extent necessary for the purposes of processing payments, refunding payments and dealing with complaints and/or queries relating to payments andrefunds;
● Whatsapp as reasonably necessary to give you the option to chat with one of our support service representatives;
We may disclose Transport Partner personal information (name, phone number, vehicle details) to you as reasonably necessary for the purposes of providing the transportation services you have requested. You are only allowed to use and retain this personal information to allow the service you have requested to complete.
How long we keep your data
We will not keep your personal data for longer than we need to, the period for which we will keep your personal data will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal data for a longer period, or where we may need to retain information in case of legal claim.
In some circumstances 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.
How we protect your data
We implement appropriate technical and organisational measures to protect data that we process from unauthorised disclosure, use, alteration, or destruction.
In addition to the technical and organisational measures we have put in place, there are a number of simple things you can do to in order to further protect your personal information;
1. Never share a One Time Passcode (OTP).
2. Never enter your details after clicking on a link in an email or textmessage.
3. Always send confidential information by encrypted email where possible this reduces the risk of interception.
4. If you’re logged into any online service do not leave your computer unattended.
5. Close your internet browser once you’ve logged off.
6. Never download software or let anyone log on to your computer or devices remotely, during or after a cold call.
7. You can easily identify secure websites by looking at the address in the top of your browser which will begin https:// rather than http://.
Your rights in relation to your personal information
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
● 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.
● Request correction of your personal data. - 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.
● 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.
info