Privacy and Cookies Policy

Version number: 2.0
Effective date: May 25, 2019

Introduction

London Extra Services sets out in this Privacy Notice how it protects client data. London Extra Services will collect, use and store the personal information that you give us, in accordance with this Privacy Notice and in line with current data protection regulations (GDPR).

We know what data we have, and why we have it

London Extra Services collects, stores and processes personal data given by its clients, past clients and potential clients. (all collectively known as clients). We use this data pursuant to our matching contract with you or for taking steps to enter into a contract with you . This may include some or all the following:

  • Name, address, phone, email, mobile
  • Client personal information: gender, age, height, hobbies, etc
  • Client photo
  • Client ID
  • Client matching preferences
  • Client contract
  • Financial Information
  • IP Address
  • Other relevant data

We may also use the health, political and religious data that you give us with your permission in the matching process.

You may request the deletion of your personal data at any time by contacting your personal matchmaker or the London Extra Services Office Manager.

We understand and comply with individual’s rights

London Extra Services Clients have the following rights:

  • Clients have the right of access to their data (NB this does not apply where it includes data of a third party such as feedback received from a match)
  • Clients have the right to have inaccurate personal data rectified
  • Clients have the right to have their data erased (but this will only apply in relation to your own account and will not include where a third party has given feedback)
  • Clients have the right to request the restriction or suppression of their personal data
  • Clients have the right of data portability in relation to images or digital content which they have supplied to London Extra Services
  • Clients have the right to object to the use of their data where we are using it on the basis of our legitimate interests and your interests outweigh our own legitimate interests
  • Clients have the right to be notified if a data breach occurs in certain circumstances where it may cause them harm or possibility of serious harm

We manage client data in a structured way

Client data is gathered from clients by London Extra Services matchmakers and continually updated using client reviews and match feedback by phone, face to face, email, in writing or other medium.

Client data will be used:

  • During the client matching process
  • To keep records as required of clients
  • To comply with the Law and/or our Matchmaking Regulator’s requirements
  • To verify client identity by searching publicly available records
  • To keep track of financial transactions
  • With your permission or lawfully to update you by phone email etc on our events, products and services and those of our Group Companies
  • For our legitimate business purposes for internal business analysis

Your personal data will be retained only for as long as necessary to fulfil the purposes for which we collected it and in relation to certain data, for example, relating to the services provided and billing transactions, for a period of approximately 6 years from the end of the contract.If there is continued contact with the client/potential client on an ongoing basis (minimum once every 2 years), the personal data will continue to be retained.

We know who is responsible for the data we have

London Extra Services has a Data Protection Officer, who, together with London Extra Services Matchmakers are responsible for data analysis, input and retrieval. Only key people involved in the matchmaking process have access to this data.

Our IT and data storage are managed outside the EEA in Canada which has been granted adequacy for handling EU data. These 3rd party companies we deal with are not allowed to sell, share or use our clients’ data for their own purposes.

We have a data security awareness and culture

  • Our staff receive data protection training and they are all briefed on London Extra Services Privacy Notice and practices.
  • We will never sell, share or permit use of clients’ data out-with London Extra Services group companies own processes except when required by law, legal proceedings , or to protect you or a third party’s safety.

We have data security processes and procedures

  • The main client database is backed up daily
  • The local database backup is regularly backed up and stored securely within the UK with restricted access
  • Computers and access are password protected
  • Only key London Extra Services personnel have access to allow download or deletion of client records
  • Client records will be archived or deleted after there is no interest in the record for the client or London Extra Services
  • Client records will be archived or deleted after there is no interest in the record for the client or London Extra Services
  • London Extra Services offices are kept locked when unoccupied and hard copy documents are stored in locked cabinets

We have a process for how and when we contact clients

London Extra Services in contract clients

  • London Extra Services will be in contact by phone, text, email, in writing and in person with in-contract clients to fulfil their contract.

London Extra Services out of contract & potential clients

  • From time to time, London Extra Services will be in contact by phone, text or email or in writing.
  • London Extra Services may be in contact if there is a potential suitable match for them or to ask if they wish to start a new contract with London Extra Services, to check on the progress of a relationship or to check whether they would like to remain on the London Extra Services database.

We have a process for how we delete client records

If requested by the client, a client record will be entirely deleted from the London Extra Services database except in the following case:

When complete deletion of a client record on the database would also delete the record of matches completed with other London Extra Services clients, London Extra Services may decide that the entire client record should not be deleted. However, phone number, email address and correspondence addresses will be deleted. Client name will be anonymised.

Entire deletion of a client record will be made on the authority of the CEO.

We have a process for client requests for their personal data

London Extra Services is committed to giving people access to their personal information. Clients can make a “Subject access request” under GDPR for their personal information.

Requests for personal information must be made in writing to the Office Manager at London Extra Services. You will not need to pay a fee for this. We will aim to respond to your request within 30 days, but if this is not possible due to the nature of the request, we will inform you of this as soon as possible, giving you an estimated timeframe for sending you the information requested. Data may be sent electronically or by hard copy

Clients do not have the right to other people’s data, or data that has been produced about them through either meeting with or analysis by the matchmaker or personal feedback from other clients they have been matched with.

We understand our lawful basis for processing your data

Under GDPR, London Extra Services uses Contract and Legitimate Interest as the basis for lawful processing of client data.

Contract (in contract clients)

In contract clients will have the information and data freely provided by them (para1) processed as necessary to allow fulfilment of the contract with London Extra Services.

Potential clients who have been in contact with London Extra Services but not yet entered into a contract with London Extra Services will have the information and data freely provided by them (para1) processed as necessary.

Legitimate Interest (in contract clients/lapsed clients and lead/enquiries/potential clients)

In contract clients and where a lapsed client or potential client has submitted or had their details submitted to London Extra Services demonstrating their interest in London Extra Services or finding a partner or to be matched, that is considered a legitimate interest. London Extra Services may contact that client/potential client regarding: updating their details, availability of or for a match, changes to product and service, promotional material.

Visitors to our website

When someone visits our website, londonextra.net, we use a third-party service, Google Analytics to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not allow Google to make any attempt to find out the identities of those visiting our website.

Changes to the Privacy Notice

London Extra Services Privacy Notice may be updated from time to time. London Extra Services will not reduce your rights under this Privacy Notice without your explicit consent.

How to contact us

To contact us regarding your personal information or request information about our privacy policy, you can email or write to: Contact.

 

1.
Who are we?
1.1
We are London Extra Services trading as “London Extra Services”. For privacy queries, you can contact us at Contact. Other contact details are on our website.
2.
What’s the point of this policy?
2.1
It tells you what to expect when we collect your personal information via our website or by phone. Please only use our service if you are completely happy with this policy.
2.2
Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies.
3.
Might the policy change?
3.1
Yes. Please check it whenever you visit our website. We will assume you agree to the new version of the policy if you use the site after its effective date. We may also notify you of any changes by email or in-service message.
4.
What do we collect?
4.1
Information which you upload to our service or otherwise give us such as:

  • your name and contact details;
  • other information provided when you make an application through us such as date of birth, nationality, marital status, visa status, employer information;
  • details about your transactions on our service; and
  • your communications with us.
4.2
Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions.
4.3
The following information about you may be provided to us by other people:

  • Limited billing information sent to us by our payment provider for verification purposes e.g., your name, email address and billing / delivery addresses.
5.
What’s our reason / legal basis for collecting the information?
5.1
Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract, e.g., send service messages, process payments and fulfil orders. This applies to initial enquiries and to contact and transaction details and other information which you provide in connection with your application.
5.2
Because it’s in our “legitimate interests”, e.g., to manage and improve our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to automated usage data.
6.
How long do we keep personal information?
6.1
For up to 180 days after you make your application via our service. You can request that your information is deleted earlier by emailing us at the above email address.
6.2
We may hold on to some of your information for longer (typically up to six years) if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions.
7.
To whom do we send or make available your personal information?
7.1
To other people who supply us with a service, e.g. website hosts, payment providers, couriers and businesses which help us send communications or monitor our website and which provide us with e-commerce, analytics and other IT services.
7.2
To the relevant official body in connection with your application.
7.3
To credit reference agencies, regulators and the police and other law enforcement authorities to help deal with fraud and abuse and/or comply with legal requirements.
7.4
To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.
7.5
To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
8.
Do we send your information outside the European Union?
8.1
Your personal information which we collect is stored within the EU and is not transferred to any third countries except as follows.
8.2
Your personal information may be transferred to the US by the following companies certified under the EU-US Privacy Shield Framework, which provides certain safeguards for your personal information: Google (analytics).
9.
What rights do you have?
9.1
If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g. marketing).
9.2
You may also have the right to object to use of your personal information in certain circumstances.
9.3
If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).
9.4
For more information about your rights, visit the ICO’s website: www.ico.org.uk.
10.
What about cookies?
10.1
We and/or other companies use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your web browser. Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Some are session temporary “session” cookies that remain in the cookie file of your browser only until your browser is closed. Whereas persistent cookies stay for longer (depending on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete existing cookies, visit: www.allaboutcookies.org. Our site’s functionality will be limited if you configure your browser to reject cookies.
10.2
We ourselves may place the following types of cookies:

Type of cookies Purpose
Logged-in status Assess whether you are logged in to our site
“Remember me” Remember you and speed up your login when you return to our site
Authentication Identify and authenticate you to help you move easily through the site
Shopping cart Remember contents of your cart and related preferences
Cookie notice Store your response to our cookie notice
10.3
Companies which provide us with a service also place cookies. Some of these cookies (e.g. from Google) may involve certain information, such as your IP address and web address of the page you’re visiting, being sent to the company concerned. Below is a summary of the kinds of cookies used together with details about who places them and where you can go to get more information and to opt out (where possible):

  • Analytics cookies: These kinds of cookies recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and where the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. These cookies are provided by: