Privacy Policy
BACKGROUND:
This Policy applies as between you,
the User of this Web Site and Life Champions Trading as CDF
Services Ltd, the owner and provider of this Web Site. This Policy
applies to our use of any and all Data collected by us in relation
to your use of the Web Site and any Services or Systems therein.
Use of any of our products, services and features confirms
acceptance of this policy.
1. Definitions and
Interpretation
In this Policy the following terms
shall have the following meanings:
Term Definition
“Account” means collectively the
personal information, Payment Information and credentials used by
Users to access Material and / or any communications System on the
Web Site;
“Content” means any text, graphics,
images, audio, video, software, data compilations and any other
form of information capable of being stored in a computer that
appears on or forms part of this Web Site;
“Cookie” means a small text file
placed on your computer by CDF Services Ltd when you visit certain
parts of this Web Site. This allows us to identify recurring
visitors and to analyse their browsing habits within the Web Site.
Where e-commerce facilities are provided, Cookies may be used to
store your session details, purchase tracking, product listings,
site movements. Further details are contained in Clause 10 and
Schedule 1 of this Policy;behavourial tracking cookies may also be
used to improve the relevancy of products, services and advertising
used throughout our site and 3rd party sites we link to in order to
offer you a range of rewards, benefits, discounts and deals.
“Client” means a company using the
Life Champions platform and technical environment to provide
rewards, benefits, discounts, deals, communications and alerts;
“Data” means collectively all
information that you submit to the Web Site. This includes, but is
not limited to, Account details and information submitted using any
of our Services or Systems;
“CDF Services LTD”Means CDF
Services Ltd trading as Life Champions, Palladia Court 25
Southampton Buildings, London WC2A 1AL;
"Member profile information" means
all information collected by us during any interaction you may have
with our sites, products, services, response centres, digital
communications;
“Service” means collectively any
online facilities, tools, services or information that CDF Services
Ltd makes available through the Web Site either now or in the
future;
“Socio economic profiling” means
the use of one or more reference services such as “ACORN” profiles
to identify marketing segments based on post code information;
“System” means any online
communications infrastructure that CDF Services Ltd makes available
through the Web Site either now or in the future. This includes,
but is not limited to, web-based email, message boards, live chat
facilities and email links;
“User” / “Users”means any third
party that accesses the Web Site and is not employed by CDF
Services Ltd and acting in the course of their employment; and
“Web Site”means the website that
you are currently using and any sub-domains or related sites
of this site (e.g. http://www.mylcaccount.com) unless expressly
excluded by their own terms and conditions;
2. Data Collected
Without limitation, any of the
following Data may be collected:
2.1 name and title;
2.2 date of birth;
2.3 gender;
2.4 job title;
2.5 profession;
2.6 contact information such as
email addresses and telephone numbers; calls, SMS, support chats
collected during the provision of service or products to you;
2.7 demographic information such as
post code, preferences and interests, socio economic profile;
2.8 financial transaction
information such as which of our services you use and the
transactions you make with your Life Champions prepaid card
and any Life Champions branded website or service, or from links
promoted to you during your membership with us;
2.9 IP address (automatically
collected);
2.10 web browser type and version
(automatically collected);
2.11 operating system
(automatically collected);
2.12 a list of URLS starting with a
referring site, your activity on this Web Site, and the site you
exit to (automatically collected); and
2.13 Cookie information (see clause
10 below).
For the avoidance of doubt we never
sell or rent your member profile information to any third
party. If you are a member of an organisation that is using our
platform to provide rewards, benefits, discounts and deals then may
report to them the category of transaction but not the details of
the individual transaction. Our system provides our Clients with
trend information about Account Holders. Personal information about
your transactions do not leave our secure environment. We may work
with 3rd party service providers and use annonymised member profile
information in order to provide you with an optimised
service. When you visit a third party site that site may
contain cookies and tracking and you should read and take note of
the service providers own site policies and provides as listed in
their T&Cs, Data Protection and Privacy Policy statements for
more detailed information about how they use that information.
3. Our Use of Data
3.1 Any personal Data you submit
will be retained by CDF Services Ltd for as long as you use the
Services and Systems provided on the Web Site. Data that you may
submit through any communications System that we may provide may be
retained for a longer period of up to 7 years in accordance with
regulatory requirements pursuant to the issue of prepaid
MasterCard® and Visa cards; regulated by the Financial Services
Authority or SEC dependant on the country of residence.
3.2 Unless we are obliged or
permitted by law to do so, and subject to Clause 4, your Data will
not be disclosed to third parties. This includes our affiliates and
/ or other companies within our group.
3.3 All personal Data is stored
securely in accordance with the principles of the Data Protection
Act 1998. For more details on security see clause 9 below.
3.4 Any or all of the above Data
may be required by us from time to time in order to provide you
with the best possible service and experience when using our Web
Site. Specifically, Data may be used by us for the following
reasons:
3.4.1 internal record keeping;
3.4.2 improvement of our products /
services;
3.4.3 transmission by email of
promotional materials that may be of interest to you, based on past
purchase patterns or socio economic profiling;
3.4.4 contact for market research
purposes which may be done using email, telephone, fax or mail.
Such information may be used to customise or update the Web Site
and/or provide profile based representation of the rewards,
benefits, discounts and deals that may best suit your needs.
4. Third Party Web Sites and
Services
CDF Services Ltd may, from time to
time, employ the services of other parties for dealing with matters
that may include, but are not limited to, payment handling,
delivery of purchased items, search engine facilities, advertising
and marketing. The providers of such services may have access to
certain personal Data provided by Users of this Web Site. Any Data
used by such parties is used only to the extent required by them to
perform the services that CDF Services Ltd requests. Any use for
other purposes is strictly prohibited. Furthermore, any Data that
is processed by third parties must be processed within the terms of
this Policy and in accordance with the Data Protection Act
1998.
5. Changes of Business Ownership
and Control
5.1 CDF Services Ltd may, from time
to time, expand or reduce its business and this may involve the
sale of certain divisions or the transfer of control of certain
divisions to other parties. Data provided by Users will, where it
is relevant to any division so transferred, be transferred along
with that division and the new owner or newly controlling party
will, under the terms of this Policy, be permitted to use the Data
for the purposes for which it was supplied by you.
5.2 In the event that any Data
submitted by Users will be transferred in such a manner, you will
be contacted in advance and informed of the changes. When contacted
you will be given the choice to have your Data deleted or withheld
from the new owner or controller.
6. Controlling Access to your
Data
6.1 Wherever you are required to
submit Data, you will be given options to restrict our use of that
Data. This may include the following:
6.1.1 use of Data for direct
marketing purposes; and
6.1.2 sharing Data with third
parties.
6.1.3 ability to allow or prohibit
communication from CDF or from a co-branded membership Client that
you have registered for through our platform.
7. Your Right to Withhold
Information
7.1 You may access certain areas of
the Web Site without providing any Data at all. However, to use all
Services and Systems available on the Web Site you may be required
to submit Account information or other Data.
7.2 You may restrict your internet
browser’s use of Cookies. For more information see clause 10.4
below.
8. Accessing your own Data
8.1 You may access your Account at
any time to view or amend the Data. You may need to modify or
update your Data if your circumstances change. Additional Data as
to your marketing preferences may also be stored and you may change
this at any time.
8.2 You have the right to ask for a
copy of your personal Data on payment of a small fee (£10 or the
$20 for US residents).
9. Security
9.1 Data security is of great
importance to CDF Services Ltd and to protect your Data we have put
in place suitable physical, electronic and managerial procedures to
safeguard and secure Data collected online.
10. Cookies
10.1 CDF Services Ltd may set and
access Cookies on your computer. Cookies that may be placed on your
computer will be added to the table below as they are deployed on
the site.
10.2 A Cookie is a small file that
resides on your computer’s hard drive and often contains an
anonymous unique identifier and is accessible only by the web site
that placed it there, not any other sites.
10.3 You may delete Cookies,
however you may lose any information that enables you to access the
Web Site more quickly.
10.4 You can choose to enable or
disable Cookies in your web browser. By default, your browser will
accept Cookies, however this can be altered. For further details
please consult the help menu in your browser. Disabling Cookies may
prevent you from using the full range of Services available on the
Web Site.
11. Changes to this Policy
CDF Services Ltd reserves the right
to change this Privacy Policy as we may deem necessary from time to
time or as may be required by law. Any changes will be immediately
posted on the Web Site and you are deemed to have accepted the
terms of the Policy on your first use of the Web Site following the
alterations.