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1. Purpose of Privacy Policy

This privacy policy ("Privacy Policy") describes how we, SquareTrade Limited (a company registered in England and Wales, with company number 07165194, whose address is Unit 1.02 1-2 Hatfields Enterprise House, London, SE1 9PG) ("We", "Our" or "Us"), processes and share personal information of collected about you when you use Our website, www.squaretrade.co.uk (the "Site").

This Privacy Policy also explains how your personal information will be transferred to Our parent company in the US, SquareTrade Inc., from the European Economic Area (comprising the member states of the European Union, Liechtenstein, Norway and Iceland) (the "EEA") and how We collect, use, and disclose such data in compliance with the EU-U.S Privacy Shield Framework administered by the U.S Department of Commerce (" Privacy Shield").

This Privacy Policy does not apply to websites, applications, or services that do not display or link to this statement or that display or link to different privacy statements.

2. Information We Collect

We collect information about you in various ways when you use Our Site. We may automatically collect certain information from you regarding your use of Our Site. For example, when you visit Our Site your computer's operating system, Internet Protocol (IP) address, access times, browser type and language, and the website you visited before Our site are logged automatically. We gather this data so We can analyse how you use Our Site, improve and customise Our content, product offerings, layout and services.

Some examples of personal information that We (which includes Our third party service providers) may collect and process include:

  • device/browser information;
  • your name;
  • mailing address;
  • phone number;
  • credit card information;
  • your IP address;
  • your location (if you are using one of Our mobile applications) and/or
  • other information you provide us on Our Site. We may also obtain information from other sources and combine that with information We collect on Our Site.

In addition, We may use and share your personal information with Our affiliates, subsidiaries, and partners and with third parties for purposes of follow-up communications, notices, and, where you have given Us your consent to do so, marketing.

We will transfer the personal data described in this section to the U.S under the Privacy Shield. We explain what the Privacy Shield is and the protections that it offers you at section 5 and section 7 of this Privacy Policy.

3. Cookies

Cookies. We may automatically collect information using "cookies".  A cookie is a small data file stored on your hard drive by a website. Cookies help Us make Our Site and your visit better. We use cookies to see which parts of Our Site people use and like and to count visits to Our Site.
You were given the opportunity to consent to Our using cookies as you entered the website. By continuing to browse the website you consented to this. However, if you wish to do so, you can change your browser settings to reject cookies. Most web browsers automatically accept cookies, but you can generally change your browser's settings to display a warning before accepting a cookie, or to block all cookies. However, please note that if you choose to disable the receipt of cookies, certain features of the Site may not function properly or may be unavailable. Visit www.aboutcookies.org to learn about how to delete and control cookies using the main browser types.

Cookies We use on www.squaretrade.co.uk are as follows:

First party cookies (placed by Us)

Cookie name

Function

Duration

Provider

JSESSIONID

Manage Cart and User Dashboard

Session

SquareTrade

Has_js

Informs content management system whether javascript enabled in browser settings

2 years

SquareTrade


Third party cookies (placed by others)

Cookie name

Function

Duration

Provider

_utma

Gather analytics

2 years

Google
(see http://www.google.com/intl/en/policies/privacy for more information, including on how to delete or reject these cookies)

_utmb

Gather analytics

30 mins

_utmc

Gather analytics

Session

_utmz

Gather analytics

6 months

km_ai

Gather analytics

5 years

Kissmetrics
(see https://www.kissmetrics.com/privacy for more information, including on how to on how to delete or reject these cookies)

km_lv

Gather analytics

5 years

kvcd

Gather analytics

Session

km_vs

Gather analytics

30 minutes

optimizelyBuckets

Gather analytics

10 years

Optimizely
Optimizely (see https://www.optimizely.com/privacy/ for more information, including on how to delete or reject these cookies)

Optimizely

Gather analytics

10 years

Pixel Tags. We may collect information using pixel tags. Pixel tags are small blocks of code that may be used on Our Site or in Our emails. We use pixel tags to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.

Third Party Advertisements. We may also use third parties to serve ads on Our Site or to manage Our advertising on other Site. Certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit Our Site (but not your name, address, email address or telephone number). They do this by using cookies, pixel tags and other technologies. Information about your activities on this and other websites may be used, among other things, to provide you targeted advertising based upon your interests, and to better understand the usage and visitation of Our Site and the other sites tracked by these third parties. Please note that this Privacy Policy does not apply to, and We are not responsible for tracking and/or the usage of cookies and similar technologies by third party advertisers. You are encouraged to read the privacy policies of those advertisers' or other third parties' websites or applications to learn about their use of cookies and other technology. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.aboutads.info/choices.

[Mobile. When you download or use apps created by SquareTrade or Our subsidiaries, We may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices provide users with the ability to turn off or disable location services. Most likely, these controls are located in the device's settings menu. If you have questions about how to disable your device's location services, We recommend you contact your mobile service carrier or your device manufacturer.]

4. Our Use of Your Information.

We use personal information collected through Our Site for purposes described in this Policy, including in connection with the provision of Our services or as otherwise notified to you on Our Site or by email from time to time. We will use your information to:

  • operate and improve Our Site, products, and services;
  • understand you and your preferences to enhance your experience and enjoyment using Our Site, products, and services;
  • respond to your comments and questions and provide customer service;
  • provide and deliver products and services you request;
  • to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
  • communicate with you about promotions, upcoming events, and other news about products and services offered by Us and Our selected partners;
  • link or combine your information with other personal information We get from third parties, to help understand your needs and provide you with better service.
5. Disclosure of Your Information to Third Parties

We share your personal information with third parties as follows:

  • With Our third party vendors, consultants, and other service providers who work for Us and need access to your information to provide these services to Us and perform certain functions on Our behalf. These third parties will have access to your information only for purposes of performing these services or tasks on Our behalf.
  • We may share some or all of your personal information with Our parent company, subsidiaries, joint ventures, or other companies under a common control (“Related Companies”) for the purposes of internal administration and management, delivering the service, marketing, internal analytics, data management and technical support. When We share information with Our Related Companies We will require them to honor this Privacy Policy.
  • We may share some or all of the personal information We obtain you when performing these services to third parties in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of Our business or assets to another company (in such case, the company with whom We share such information will process your personal information in accordance with their privacy policy
  • We may transfer your personal information to another party if We become insolvent or otherwise cease trading and such third party shall then process your personal information in accordance with their privacy policy.
  • With insurers for the purpose of providing insurance and handling claims and repairs;
  • in certain circumstances with your express consent; and/or
  • To (i) protect the rights and property of Us, Our agents, customers, members and others including to enforce Our agreements, policies and terms of use, or (ii) in an emergency to protect the personal safety of Us, Our customers, or any person.

In order to fulfill the purposes set out above, We reserve the right to disclose personal data to law enforcement agencies, regulatory bodies, government agencies and other third parties at Our discretion as required by law or for administration purposes (e.g. in the UK, HM Revenue and Customs).

If We transfer your personal information including sensitive personal data, as appropriate) from the EEA to the U.S then, where required by Privacy Shield, We enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on Our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process personal data in accordance with Our Privacy Shield obligations and to stop and remediate any unauthorised processing.

Under certain circumstances, We may remain liable for the acts of Our third-party agents or service providers who perform services on Our behalf in connection with their handling of personal data that We transfer to them (including where We transfer personal data to them pursuant to the Privacy Shield).

If We transfer your personal data to SquareTrade, Inc. in the US. We will take steps to ensure that your personal data is protected as required by the Privacy Shield.

6. Where We Store Your Information

We will store, transfer and otherwise process personal information We collect from you in the United States and other countries including but not limited to the European Union member countries. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7. International Transfers

We will transfer your personal data (as described in section 2) to SquareTrade, Inc. in the US who will process your personal data in the US for the purposes set out in section 4 of this Privacy Policy.

We recognize that the EU has established strict positions regarding the handling of personal data (including sensitive personal data, as appropriate) including requirements to provide adequate protection for personal data collected within the EEA and transferred outside the EEA. We will ensure that We only transfer personal data to a country or territory outside the EEA if that country or territory ensures an adequate level of protection for the rights and freedoms of individuals in relation to the processing of personal data or where adequate contractual safeguards to protect that data are in place.

EU-US Privacy Shield

SquareTrade Inc. has elected to self-certify to the EU-US Privacy Shield Framework.

SquareTrade Inc. adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

Principle 7, the Accountability for Onward Transfer Principle, means that SquareTrade Inc. remains potentially liable if a third party processing your personal data processes that personal data in a way which is inconsistent with the Privacy Shield Principles (unless SquareTrade Inc. can prove that it is not responsible for the event giving rise to the damage).

Under certain circumstances, SquareTrade Inc. may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall take priority.

Within the United States, for the purposes of enforcing compliance with the Privacy Shield, SquareTrade Inc. is subject to the investigatory and enforcement authority of the US Federal Trade Commission.

For more information about the Privacy Shield, see the U.S Department of Commerce's Privacy Shield website located at: https://www.privacyshield.gov. To review SquareTrade Inc.'s representation on the Privacy Shield list, see the U.S Department of Commerce's Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.

8. Third Party Links and Data Collection

Our policy only addresses the use and disclosure of information We collect from you through Our Site or use of such data under any terms and conditions of insurance, and does not cover partners on behalf of whom We perform services, or any third-party site or their services, including social networking services that may be made available through Our Site. If you disclose your information to any third party, We suggest that you consult the privacy policies of such third parties as different rules will likely apply to their use or disclosure of your personal information.

Please be aware that We are not responsible for the privacy practices of third party websites and We cannot be responsible for personal information that third parties may collect, store and use through their websites.

9. Marketing

Where you have given Us your consent to do so, We (or third party data processors acting on Our behalf) may:

  • contact you (including by SMS and e-mail) with products and services which We think may interest you; and/or
  • disclose your personal information to carefully chosen third parties so that they may contact you (including by SMS and e-mail) with products and services which they think may interest you.

If We send you marketing or promotional emails, you will have the opportunity to opt out from such emails either by (a) clicking on the "unsubscribe" link that appears in all of Our emails or (b) by contacting Us via e-mail at privacy@squaretrade.com.

If you opt out, We may still send you non-promotional emails, such as emails about your accounts, Our ongoing business relations or to respond to requests and inquiries.

10. Access to Information

You have the right to access the personal data We collect about you in the EEA and to request that We correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where We must comply with legal requirements or if providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access.

If you would like to request access to, correction, or deletion of your personal data collected in the EEA, you can submit a written request to the contact information below in Section 13. We may request specific information from you in order to confirm your identity. In some circumstances, We may charge a reasonable fee for access to your information.

11. Security of Your Personal Information

Confidentiality and security of your personal information are very important to Us. We have implemented appropriate administrative, technical and physical security measures (including in accordance with the Privacy Shield) designed to protect your information from loss, unauthorised access, use, modification or disclosure, including the use of encryption and other technology safeguards to reduce security risks.

We review Our internal security policies and guidelines from time to time to take into account new technology and methods, the risk represented by the processing and the nature of the data being protected. We limit access to Our databases containing personal data to authorised persons having a justified need to access such information and limit retention periods to retain data for no longer than is necessary.

12. Questions or Complaints

You can direct any questions or complaints about Our collection, use and storage of your personal data by email to privacy@squaretrade.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal data within 45 days of receiving your complaint.

If you are unsatisfied with the resolution of your complaint, you may contact the UK Information Commissioner's Office or the relevant EU data protection authority using the contact details located at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm for further information and assistance.

Complaints related to transfers of your personal data from to SquareTrade Inc. in the U.S.

We follow internal procedures for verifying that Our commitments under this Privacy Policy have been implemented, and will remedy problems arising out of a failure to comply with this Privacy Policy and (if applicable) the Privacy Shield Principles.

We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to TRUSTe. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, https://feedback-form.truste.com/watchdog/request.

If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Us, you may contact TRUSTe.

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly Us using the contact details above and provided Us the opportunity to resolve the issue; and (2) raised the issue through the relevant data protection authority and allowed the U.S Department of Commerce an opportunity to resolve the complaint at no cost to you. For further information on your option to select binding arbitration see Annex I of the Privacy Shield Principles located at: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

13. Contact Information

We welcome your comments or questions about this Privacy Policy or the practices described herein. To request access to, changes, or updates to your information please contact Us at privacy@squaretrade.com.

You can contact SquareTrade Limited at: The Data Protection Officer, SquareTrade Limited, Unit 1.02 1-2 Hatfields Enterprise House, London, SE1 9PG, United Kingdom.

You may also contact Us at: SquareTrade, Inc. Attn: Legal Department, 360 3rd Street, 6th Floor, San Francisco, CA 94107, United States of America.

14. Modifications to this Policy

We may change Our Privacy Policy from time to time (including for consistency with the Privacy Shield's requirements) and will denote the date of the policy by changing "Last Updated" date below. We will provide additional notification if these changes are material.

Last updated 30 November 2016

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SquareTrade Limited is authorised and regulated by the Financial Conduct Authority under registered number 538538. SquareTrade Limited Registered in England No. 7165194.