Privacy policy

This Website is owned and operated by Always Hear.

 This Policy explains how we collect and use your information. In this Policy, “we”, “us” and “our” means Always Hear.

 You have certain rights in relation to your data, including the right to object to processing based on legitimate interests, profiling (including the use of custom and lookalike/similar audiences), and direct marketing. At any time, If you have any questions about this Policy, or would like to exercise your rights, you can email our Data Protection Officer at [email protected] For further details about our processing and your rights, please see below

ABOUT THIS SITE

Our site enables people to request quotes, information or comparisons for the product or service shown or selected on this site.

We want to give you the best possible experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you the opportunity to be contacted by one of our partners.

The data privacy law allows this process to happen as part of your legitimate interest in the promoted product or service. Of course, if you wish to change how we use your data you always hold this right.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide the best experience.

Here’s how we’ll use your personal data and why:

To process any product or service enquiries we need to collect your personal data. If we don’t collect your personal data during our process, we won’t be able to pass your information through to our partners as this would not comply with our legal obligations. We will retain those details for a reasonable period afterwards in order to fulfil contractual obligations. Once this time has passed any information held will be deleted.

To respond to your queries. Handling the information, you sent enables us to respond. We may also keep a record of this to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

To protect our business and yours from fraud and other illegal activities. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

To market our partners’ products and services to you. We will use your personal data, preferences and details of your transactions to keep you informed by email, web and telephone about relevant content, products and services including information, tailored offers, discounts, promotions, events, competitions and so on. We market on the basis of legitimate interest and in a way which might reasonably be expected as part of running our business.

HOW OUR SITE WORKS

If you’d like to request and receive quotes or information for the Product, please complete and submit the webform with our partner websites.

Once our/your request has been received, you’ll be connected with one or more relevant Service Providers. We’ll tell the Service Providers who you are, and your Product requirements, and they’ll then contact you directly with your requested Quotes.

For certain products, before connecting you with relevant Service Providers, you may be called to confirm your details or requirements.

You’ll see on our webform that we have a really clear consent statement. This statement sets out the Service Providers that will contact you.

You can choose which Service Provider to buy from. But you don’t have to buy from any of them. There’s no obligation to purchase.

We don’t work with any Service Providers until we have a legal contract in place. This is to ensure that they respect your data and rights by keeping your data secure and confidential, limiting their use of your data (i.e. to providing you with the requested Quotes), and not sharing your data with anyone else.

Legal Processing

Data protection law states there are several legal reasons why a company may collect and process personal data.

Contract − We will process your personal data to fulfil an order, deliver a service, essentially comply with our contractual obligations.

Legal Compliance − If the law or government requires us to, we may need to collect and process your data. An example might be passing on details of fraud to law enforcement.

Legitimate Interest − In cases, we require personal data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business. This does not impact your freedom or rights. Examples might be using your postal or email details to send direct marketing information on content, products and services that we think might interest you with the aim of raising awareness of our business with yours and you, as an employee of that business. We may also use your browsing or purchase history to send you or make available personalised offers.

When do we collect, add to or amend your personal data?

When you visit any of our websites or speak to us on the phone.

When you purchase a product or service or enter into negotiations to do so.

When you engage with us on social media.

When you contact us by any means with queries, complaints etc.

When you book any kind of appointment with us or book to attend an event, for example a meeting to discuss an opportunity.

When you choose to complete any surveys we send you.

Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.

When you have third party permission to share with us the information they hold about you.

We may collect data from publicly-available sources where you have given your consent for them to share information publicly such as online directories or LinkedIn.

What sort of personal data do we collect?

Contact details such as email address and phone number

Details of your interactions with us through phone contact, email or online.

Details of your visits to our websites, and which site you came from to ours.

Information gathered by the use of cookies in your web browser.

To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.

Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

WHAT WE DON’T DO WITH YOUR DATA

Before confirming what data we collect, and why, here’s what we definitely don’t do with your data, unless clearly set out in this notice:

We don’t share it with anyone else.

We don’t use it for any purpose (including retargeting, commingling across multiple advertisers’ campaigns or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis, and only to assess the performance and effectiveness of our advertising campaigns.

We don’t use it to build, append to, edit, influence or augment user profiles, including profiles associated with any mobile device identifier or other unique identifiers that identify any particular user, browser, computer or device.

We don’t transfer it (including any anonymous, aggregate or derived data) to any advertising network, advert exchange, data broker, or other advertising or monetisation-related service.

HOW WE USE YOUR DATA

We use your data (described above) in the following ways.

To connect you with relevant Service Providers

As explained above, if you submit our webform, we’ll pass your request to one or more relevant Service Providers (named on the consent statement). We will do this in a secure way. For example, using HTTP Secure (HTTPS), which means the data is encrypted. The Service Providers then contact you directly with your quotes. They may contact you by telephone, text/SMS or email.

Before we pass your request to any Service Providers, our service may involve an element of automated decision-making. Our technology platform may automatically assess your Product requirements and pass your request to such Service Providers that would like to receive requests for Quotes at the time your request is made.

We store IP addresses in order to stop unwanted traffic (i.e. spam) to our site. For example, if we become aware that spam is coming from a particular IP address (i.e. computer or location), we can block that IP address. From time to time, we also share IP addresses with Service Providers to enable Service Providers to verify that requests for Quotes have come from a particular country.

To call you to confirm your details or requirements

For certain products, before connecting you with relevant Service Providers, we may call you to confirm your details or requirements.

We may also call you to ask about your experience using our site and service, and dealing with the Service Providers with which we connected you.

To email you about similar products and services – But only if you haven’t opted out of such emails

If you use our quote request service, then, as an existing user, we would like to email you, or send you text/SMS messages, about similar products and services for which we think you might like quotes or information.

You will always be given an opportunity to opt out of such messages before we send them, and we will not send such messages if you have opted out.

To create custom and lookalike/similar audiences

We like to work with Facebook, Google and other platforms to reach out to you with adverts for Other Products. We also like to use Platforms to reach out to other people who might like to use our quote request service.

We do this in two ways. In both cases, your data, along with other data, is used to create a custom audience and/or a lookalike/similar audience. Whenever an audience is shared with a Platform, the data is first hashed and pseudonymised, meaning that any data within the audience that could identify a person is replaced with an artificial identifier. So, the process is secure. Also, we don’t share more data than we need to for the purpose of creating the audience.

Receiving data from Service Providers

From time to time, Service Providers may return data to us. They may do this if they have a query regarding a request for Quotes that we have sent to them in order to enable us to resolve the query. They may also return data to us, together with confirmation on whether or not a product has been purchased, in order to enable us to improve our marketing. We may also use such data to create custom and lookalike/similar audiences, as explained above.

Our Website uses cookies to distinguish you from other users of the Website, to provide you with a good experience when you browse the Website, and also to help us to improve the Website.

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.

You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

 On our Website we use the following kinds of cookies:

Strictly necessary cookies. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

Performance cookies. These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

Functionality cookies. These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Targeting cookies, or advertising cookies. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

 Managing cookies

You can remove any cookies already stored on your computer and you can control how your web browser deals with cookies by clicking “turn cookies off” in the “Cookie control” pop up at the bottom left corner of our Website, or by changing your browser settings. Turning cookies off may prevent you from using parts of our Website.

Many browsers give a range of options for managing cookies, including obtaining consent for every cookie, blocking certain types of cookie and blocking cookies from unrecognised websites. You can set your browser to block all cookies. However, if you do this many sites will not work as smoothly as you are used to and some basic functionality that is dependent on cookies will not work at all.

The following links go to the relevant help sections for the major web browsers and explain how to manage your cookies:

Chrome

https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies

Safari OS X

https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=en_US

Safari iOS

http://support.apple.com/kb/HT1677

Internet Explorer

https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

Firefox

http://support.mozilla.org/en-US/kb/Cookies?s=cookies&r=0&e=es&as=s

Android

https://support.google.com/chrome/answer/95647?hl=en&co=GENIE.Platform=Android

Blackberry

http://help.blackberry.com/en/blackberry-q10/10.3.1/help/mwa1334238823957.html

Windows phone

https://support.microsoft.com/en-us/help/10635/windows-phone-change-privacy-and-other-browser-setting

We use the following specific cookies:

 The __utma Cookie – This cookie is what’s called a “persistent” cookie. It is used by Google Analytics (http://www.google.com/analytics) to ascertain whether a web user is a return visitor or a new visitor, keeps track of the number of times a visitor has been to the site pertaining to the cookie, when their first visit was, and when their last visit occurred. This cookie expires after 2 years.

The __utmb and __utmc Cookies – The B and C cookies, used by Google Analytics, are brothers, working together to calculate how long a visit takes. __utmb takes a timestamp of the exact moment in time when a visitor enters a site, while __utmc takes a timestamp of the exact moment in time when a visitor leaves a site. __utmb expires at the end of the session. __utmc waits 30 minutes, and then it expires.

The __utmz Cookie – The __utmz is used by Google Analytics to keep track of where the visitor came from, what search engine you used, what link you clicked on, what keyword you used, and where they were in the world when you accessed a website. It expires in 6 months.

SQ_SYSTEM_SESSION – This cookie is used purely for the smooth technical operation of the Website.

ASP.NET_SessionId – Another cookie used for the smooth technical operation of the website. This cookie expires within 20 minutes of leaving the Website.

cc_analytics and cc_social – These cookies store the choices you make when modifying your privacy settings in the tab at the bottom of the screen. It does not store personal information about a user, it simply remembers your privacy settings ready for your next visit to the Website. Both cookies expire after 1 year.

—-atuvc – This cookie is used by AddThis (http://www.addthis.com) to allow Website users to share content on third party social media websites. This cookie expires after 2 years.

Third party cookies

We also allow other companies, called third-party ad servers or ad networks, to serve advertisements on our behalf. We do not provide any personally identifiable customer information to these advertisers or third-party websites. Currently we have relationships with the following third-party ad networks:

AppNexus.http://www.Appnexus.com.

AppNexus places cookies on the browsers of visitors to its website(s) and may send its own cookies to the visitors’ cookie file. The cookies will allow AppNexus to apply its Personalized Retargeting technology and to serve Personalized banners; AppNexus only employs anonymous cookies for Personalized banners, the Cookie is a means by which information relating to internet activity is recorded; AppNexus will collect and use this data in accordance with all applicable laws and regulations (including but not limited to laws governing privacy, and data protection); The data collected and used by AppNexus is at its sole discretion and will only contain non-personal data. This data will be anonymous and will not contain the name, address, telephone number, email address or IP address of the Visitors. AppNexus Privacy Policy can be found here http://appnexus.com/platform-policy#choices and includes information for users on how to opt-out or being cookie retargeted.

Google analytics.

Click here to see an overview of Google’s Privacy policy. (http://www.google.com/analytics/learn/privacy.html)

Facebook.

Click here to see Facebook’s cookie policy: https://www.facebook.com/policies/cookies/

Native – Taboola.

Click here to see Taboola’s cookie policy: https://www.taboola.com/cookie-policy

Outbrain.

Click here to see Outbrain’s privacy and cookie policy: https://www.outbrain.com/legal/privacy#privacy-policy.

Yahoo Gemini.

Click here to see Yahoo Gemini’s privacy and cookie policy: https://policies.yahoo.com/ie/en/yahoo/privacy/index.htm

STORING YOUR DATA

We have a data retention policy, which clearly sets out how long we keep data for, and for what reasons.

We will keep your data only for as long as is necessary to fulfil the purpose/s for which it was collected in the first place, i.e. as set out in this notice.

For example:

We will keep your request for Quotes for 6 months after you make the request to enable us to resolve any queries from Service Providers, should they arise.

If you haven’t opted out of receiving marketing from us, we will keep your details, and send you emails, until such time as you don’t engage with our emails for a period of 6 consecutive months.

Following the periods set out above, we will not use the data, save that we will hash/anonymise the same, and retain it for a further 3 years for compliance purposes.

LEGAL GROUNDS

This notice sets out (above) how we use your data. Under the GDPR, controllers must have a valid lawful basis for each processing activity that they undertake. This section sets out our lawful basis for each activity.

Activity

Lawful Basis under the GDPR

Your Rights

To connect you with relevant Service Providers

Consent

To withdraw your consent, as explained below

The automated decision-making explained above

Legitimate interests

You have the right to object to processing based on legitimate interests

Using and sharing IP addresses

Legitimate interests

You have the right to object to processing based on legitimate interests

To call you to confirm your details or requirements

Consent

To withdraw your consent, as explained below

Sharing call recordings with Service Providers

Legitimate interests

To object to processing based on legitimate interests

To email you about similar products and services

Legitimate interests*

To object to processing based on legitimate interests. You also have the right to object to direct marketing

To create custom and lookalike/similar audiences

Legitimate interests

You have the right to object to processing based on legitimate interests

Receiving data from Service Providers

Legitimate interests

You have the right to object to processing based on legitimate interests

*Under the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), we send such emails on the basis of the existing customer (soft opt-in) exemption.

In each case where we have identified legitimate interests as the legal basis for our processing, we have conducted a legitimate interests assessment.

YOUR RIGHTS

Under the GDPR, you have a number of rights. In relation to our site, and the service that we provide, those rights are set out in the table above. We further explain these rights, and your other rights, below.

Right of access – You have the right at any time to ask us for a copy of the personal information that we hold about you, and to check that we are lawfully processing it.

Right of rectification – If personal information that we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.

Right of erasure – In certain circumstances, you have the right to request that personal information we hold about you is erased (e.g. if the information is no longer necessary for the purposes for which it was collected or processed).

Right to object to or restrict processing – In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests, and there are no compelling legitimate grounds for our processing which override your rights and interests.

Right of data portability – In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.

Right to withdraw consent – In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.