Privacy Policy

INTRODUCTION

Rightsize Ltd respects your privacy and is committed to protecting your personal data. This
privacy notice will inform you as to how we look after your personal data when you visit our
website (regardless of where you visit it from) and tell you about your privacy rights and how
the law protects you.

This privacy notice is set out below. Please also use the Glossary to understand the meaning of
some of the terms used in this privacy notice.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Rightsize Ltd collects and processes
your personal data through your use of this website, including any data you may provide
through this website when you purchase a product or service.

This website is not intended for children and we do not knowingly collect data relating to
children.

It is important that you read this privacy notice together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and is not intended to override them.

Controller

Rightsize Ltd is the controller and responsible for your personal data (collectively referred to as
“the Company”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy notice please
contact the data privacy manager using the details set out below.

Contact details

Our full details are:
Full name of legal entity: Rightsize Ltd
Name or title of data privacy manager: Sarah Macnaught
Email address: sarah@right-size.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office
(ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 1 June 2020.

The data protection law in the UK changed on 25 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep
us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the privacy notice
of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the identity has been
removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we
have grouped together follows:

Identity Data includes first name, maiden name, last name, marital status, title, date of birth
and gender.

Contact Data includes billing address, email address and telephone numbers.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from
us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for
any purpose. Aggregated Data may be derived from your personal data but is not considered
personal data in law as this data does not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of users accessing
a specific website feature. However, if we combine or connect Aggregated Data with your
personal data so that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details
about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health and genetic and
biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with
you and you fail to provide that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example, to provide you with home
organising services).

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data you
provide when you
o apply for our products or services;
o subscribe to our service or publications;
o request marketing to be sent to you;
o give us some feedback directly or via a third party survey.

Automated technologies or interactions. As you interact with our website, we may
automatically collect Technical Data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies and other similar technologies. Please see our
cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from
various third parties and public sources as set out below:

Technical Data from the following parties:
(a) analytics providers (such as Google);
(b) advertising networks and
(c) search information providers

Identity and Contact Data from publicly available sources such as Companies House and
the Electoral Register based inside the EU.

4. How we use your 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 or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other
than in relation to 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
sarah@right-size.co.uk

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your
personal data, and which of the legal bases we rely on to do so. We have also identified what
our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on
the specific purpose for which we are using your data. Please contact sarah@right-size.co.uk
if you need details about the specific legal ground we are relying on to process your personal
data where more than one ground has been set out in the table below.

Purposes for which we will use your personal data

Purposes for which we will use your personal data 2

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data 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 (we call this marketing).

You will receive marketing communications from us if you have requested information from us
or purchased goods or services from us and, in each case, you have not opted out of receiving
that marketing.
Purpose/Activity Type of data Lawful basis for processing including
basis of legitimate interest

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company
outside the Company.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting
sarah@right-size.co.uk
Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service transaction.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible
with the original purpose. If you wish to get an explanation as to how the processing for the
new purpose is compatible with the original purpose, please contact sarah@right-size.co.uk

If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set
out in the table in paragraph 4 above.

• Service providers who provide it and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers.
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer or merge parts of our business or our assets.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as
set out in this privacy notice.
• We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your personal data for specified
purposes and in accordance with our instructions.

6. International transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of
protection to your personal data, so European law has prohibited transfers of personal data
outside of the EEA unless the transfer meets certain criteria.

Some of our third parties service providers are based outside the European Economic Area
(EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar
degree of security of data by ensuring at least one of the following safeguards is in place:
We will only transfer your personal data to countries that the European Commission have
approved as providing an adequate level of protection for personal data; or

Where we use certain service providers, we may use specific contracts or codes of conduct or
certification mechanisms approved by the European Commission which give personal data
the same protection it has in Europe; or

If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to
them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the
specific transfer. You will have the right to withdraw this consent at any time.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we
limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.

To determine the appropriate retention period for personal data, we consider the amount,
nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use
or disclosure of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the applicable legal
requirements.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your
personal data. Please click on the links below to find out more about these rights:

Under data protection laws you have rights in relation to your personal data that include the
right to request access, correction, erasure, restriction, transfer, to object to processing, to
portability of data and (where the lawful ground of processing is consent) to withdraw
consent.

You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/indi
vidual-rights/

If you wish to exercise any of the rights set out above, please contact Sarah Macnaught at
sarah@right-size.co.uk

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we may refuse to comply with your request in these
circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who has no right
to receive it. We may also contact you to ask you for further information in relation to your
request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us
longer than a month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.

10. Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the privacy notice
of every website you visit.

11. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites
set or access cookies. If you disable or refuse cookies, please note that some parts of this
website may become inaccessible or not function properly. For more information about the
cookies we use, please scroll down to read our Cookie Policy.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and most secure
experience. We make sure we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests are overridden by
the impact on you (unless we have your consent or are otherwise required or permitted to by
law). You can obtain further information about how we assess our legitimate interests against
any potential impact on you in respect of specific activities by contacting
sarah@right-size.co.uk.

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before
entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Service providers based in the UK who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers,
auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and
accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based in the United Kingdom who require reporting of processing activities in
certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

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 the personal data that we hold about you. 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.

Object to processing of your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you
want to object to processing on this ground as you feel it impacts on your fundamental rights
and freedoms. You also have the right to object where we are processing your personal data
for direct marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend
the processing of your personal data in the following scenarios: (a) if you want us to establish
the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase
it; (c) where you need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected to our use of your data but
we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or
a third party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the information to perform a
contract with you.

Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, we may not be able to provide certain
products or services to you. We will advise you if this is the case at the time you withdraw your
consent.

This policy was last reviewed in June 2020 and will next be reviewed in 2022

COOKIE POLICY

What is a cookie?

A “cookie” is a piece of information that is stored on your computer’s hard drive and which
records how you move your way around a website so that, when you revisit that website, it can
present tailored options based on the information stored about your last visit. Cookies can
also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system.

If you want to check or change what types of cookies you accept, this can usually be altered
within your browser settings. You can block cookies at any time by activating the setting on
your browser that allows you to refuse the setting of all or some cookies. However, if you use
your browser settings to block all cookies (including essential cookies) you may not be able to
access all or parts of our site

How do we use cookies?

We use cookies to track your use of our website. This enables us to understand how you use
the site and track any patterns with regards how you are using our website. This helps us to
develop and improve our website as well as products and / or services in response to what you
might need or want.

Cookies are either:

Session cookies: these are only stored on your computer during your web session and are
automatically deleted when you close your browser – they usually store an anonymous session
ID allowing you to browse a website without having to log in to each page but they do not
collect any personal data from your computer; or

Persistent cookies: a persistent cookie is stored as a file on your computer and it remains
there when you close your web browser. The cookie can be read by the website that created it
when you visit that website again. [We use persistent cookies for Google Analytics.]

Cookies can also be categorised as follows:

Strictly necessary cookies: These cookies are essential to enable you to use the website
effectively, such as when buying a product and / or service, and therefore cannot be turned off.
Without these cookies, the services available to you on our website cannot be provided. These
cookies do not gather information about you that could be used for marketing or
remembering where you have been on the internet.

Performance cookies: These cookies enable us to monitor and improve the performance of our
website. For example, they allow us to count visits, identify traffic sources and see which parts
of the site are most popular.

Functionality cookies: These cookies allow our website to remember choices you make and
provide enhanced features. For instance, we may be able to provide you with news or updates
relevant to the services you use. They may also be used to provide services you have requested
such as viewing a video or commenting on a blog. The information these cookies collect is
usually anonymised.

This policy was last reviewed in June 2020 and will next be reviewed in 2022

Download our privacy information PDF