Privacy Policy

1 Who are we?

Money Lowdown is owned and operated by Sable Edge Ltd registered in England and Wales under company registration number 13387746, whose registered office is at 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE. We are registered with the Information Commissioners Office. We operate under the brand name Money Lowdown and we run an investment newsletter where we promote and run marketing campaigns on behalf of some of the leading UK finance and investment brands to help them target their products and services. For those of you that register to our newsletter, you can unsubscribe or change your marketing preferences at any time by visiting https://moneylowdown.com/unsubscribe/. Our offices are at 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE or you can email hello @ sableedge.digital with your questions.

2 What do we use your data for?

The data that you provide us is for the following purpose: Direct Marketing – our brand Money Lowdown will contact you by email with our newsletter updates and offers and promotions from carefully selected companies that we believe will be of benefit to you. These offers will include but are not limited to:

• Automotive
• Charities
• Claims Management
• Competitions and Prizes
• Dating
• Deals, Offers, New Products, Services
• Education
• Electrical Services
• Employment & Recruitment
• Energy
• Entertainment, Gaming, Leisure
• Fast Moving Commerical Goods (FMCG
• Financial Products
• Funeral Plan
• Gambling and Lotteries
• Health and Beauty
• Home Improvements
• Home Improvements and Renovations
• Insurance
• Investment
• Laser Eye Surgery
• Legal
• Life assurance
• Lifestyle
• Mail Order
• Marketing Service Providers
• Mis-sold financial products
• Other
• Pension Reviews
• Pharmaceutical
• Pre-paid Funeral Plans
• Public Sector
• Publishing/Media
• Recruitment
• Retail & lifestyle
• Telecommunications
• Trace, Asset Repatriation and Debt Collection
• Travel
• Utility

Profiling – we will profile your information for marketing purposes to help our clients deliver marketing communication that is more relevant to you. We will never make automated decisions about you which would have a negative impact on your rights. You can ask us to stop processing or sharing your details at any time now or in the future. In writing to: The Data Protection Officer, Money Lowdown, Sable Edge Digital Ltd, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE. By email to: hello @ sableedge.digital

You may receive 3rd party offers in association with Click Labs Group & Client Portfolio , We Breathe Media & Client Portfolio

3 Consent and Legitimate Interests

Your data must be processed by us using one of the valid legal bases defined by the Regulations. This is summarised in the table below:

Purpose	For use by ourselves	For use by third parties
Promotion	Consent	Not applicable
Marketing – by email	Consent	Not applicable
Marketing – by SMS Consent Not applicable	Consent	Not applicable
Marketing – telephone	Consent – where your number is registered on the Telephone Preference Service.	Legitimate Interest – where your number is not registered on the Telephone Preference Service.
Marketing – by post	Legitimate Interest (where you are registered on the Mailing Preference Service we will ask for your specific consent).	Legitimate Interest – (where you are registered on the Mailing Preference Service we will ask for your specific consent).
Profiling and analytics	Legitimate Interest	Legitimate Interest

The third party partners who wish to send you marketing communications from the following categories are:

Sector	Description	Advertisers
Retail	Online retail	Hyperstech, Ted Baker, Disney, Decathalon, All Saints, Clarks, Uniqlo, Gusto, Red Letter Days, Boohoo, Reiss, Naked Wines
	Property	Purple Bricks, Yopa
	Home improvement	Anglian Home improvement, Thomas Sanderson, Price Engine,Magnet
	Telecoms and utilities	BT, Virgin Media, TalkTalk, Sky, Post Office, EE, Vodafone, Now, Plusnet, SSE, Shell Energy, ESB Energy
Finance	Pensions	True Pension, Retirement Solution, PensionBee
	Personal Borrowing and Credit	Experian, Fluent Money
	Investments & savings	Red Rock, ISA Finder, Fisher Investments
	Claims management	Pure Legal Limited
	Personal Injury	Pure Legal Limited
	Credit Reports	Experian, RS Data Tech
	Debt Management	True Debt Solution, Money Plus Group
Insurance	Home	Policy Expert, Towergate
	Car	Seopa
	Travel
	Pet	4Paws
	Business	Simplify Business
	Private Medical	Axa, True Medical Cover, PMI Quoter
	Life Insurance	Direct Life & Pensions, British Seniors, Smart Insurance
	Boiler Cover	BeSmart
Travel	Flights	SkySkanner, Air Portugal, BA, Virgin Atlantic
	Holidays	Disneyland, ClubMed, CLC Worldwide, Celebrity Cruises
	Hotel	Hotels.com, Expedia
Automotive	Breakdown Cover	RAC, AA, Green Flag
	Test Drives and Brochure Requests	Ford, Fiat, Mercedes, Jeep, DS, Skoda, Maserati, BMW, Seat, Vauxhall, Toyota, Renault, Citreon, Volvo, Nissan, Mini
Lifestyle	Laser Eye Surgery	Optimax
	Job Alert Emails	JobZooma, Restoration Media, Results Generation
	Media & publishing companies	Which? Magazine, Evo Magazone, TI Media
	Market Research	Toluna
	Gambling 18+	Mr Green, Gala, Coral, Ladbrokes, William Hill, The Sun, Jackpot Joy, Costa Bingo, Leo Vegas, Broadway Gaming, BetRegal,Football pools, Buzz Bingo, The Sun Bingo, The Sun Vegas
	Educational institutions	Kumon, Rosetta Stone, Open University,
	Health	Pharmacy2U, Lloyds Pharmacy, Echo

Consent

In short this is where you consent to a specific organisation, to contact you by a communication channel or channels which you have agreed to, for specific reasons, which in the context of our processing will be for marketing purposes. When we ask for your consent for a specific organisation, we will do so by giving you the opportunity to tick a box online or answer a question on the phone. You can of course withdraw your consent at any time and we will describe how later on in this policy.

• We obtain consent for our brands to contact you by telephone where your number is registered on the Telephone Preference Service (TPS) or by email and SMS.
• To pass your contact details to named third parties where Privacy and Electronic Communications Regulation (PECR) applies such as email marketing or where your telephone number is registered with the TPS.
• To pass your contact details to named third parties where your postal address is registered with the Mailing Preference Service (MPS).
• Where our client has specifically asked us to gain your consent to pass on your details.
• All cookies & similar technologies which do not meet the “strictly necessary” exemption under PECR.

Legitimate Interest

As a direct marketing business, we process personal information for various legitimate business purposes which include some or all of the following:

• To enhance our services for the benefit of our customers including verification and validation
• To help make the communication more relevant and contextual
• To better understand how our customers, interact with our services
• To provide direct marketing communications which we think will be of interest to you
• To determine the effectiveness of our and our client’s promotional campaigns
• To identify and prevent fraud

These legitimate business purposes relate to the following activities:

• Direct Marketing – Postal and telephone marketing by both Money Lowdown and other third parties, but in either case communications will be in relation to products or services which we believe are of interest to you based upon information which you have provided us.
• Profiling – We will profile your information for marketing purposes to help our clients deliver marketing communication that is more relevant to you (for more information, please refer to the profiling section).
• ID Protection & Tracing – This is in relation to appropriate agencies which we have listed below which could help protect your identity and prevent fraud.

We process your data in the following ways:

• To pass on your personal information to our clients for marketing purposes who will send postal marketing to you, (except where you are registered with the MPS) or contact you by telephone (except where you are registered with the TPS). Marketing will only ever be from organisations operating within the industry sectors described below.
• To call you where your telephone number is not registered on the TPS.
• To call you where we have obtained your details from a third party. We will always be named within their privacy policy as a party to whom they share your information; once contact is made we will obtain your consent at the earliest opportunity. You will always be given the option to opt out should you not wish to hear from us again.
• To process your personal information for the purposes of customer analysis, non-automated profiling and direct marketing, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
• To pass to our clients for use including tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification. More information on this can be found in the Credit References and other Agencies section.
• To determine the effectiveness of our clients promotional campaigns and advertising, and to develop our products, services, systems and relationships with you.
• Processing your information to protect you against fraud when using our website, and to ensure our websites and systems are secure.
• To pass on your details to companies to help their clients tailor products and services which best suit your needs. They will also use your data for fraud prevention. More information on this can be found in the Marketing Services Providers section.

It is important that we keep your details up to date, therefore we use various methods such as Quick Address Systems (QAS) which is a service provided by Experian Ltd, National Change of Address (NCOA®) which uses information taken directly from the redirection application forms of people who are moving and the Edited Electoral Register (EER) which contains the names and addresses of those voters who have indicated that their details can be used for a purpose other than electoral or statutory use, e.g. for direct marketing use by a commercial or other organisation. For all types of processing, we apply various measures to carefully protect your privacy rights. In considering the most appropriate legal basis, Money Lowdown conducted Legitimate Interest Assessments. These are detailed evaluations of each type of data processing activity to ensure that we have balanced the need of the processing against the rights of the individual to ensure minimal privacy impact. This documentation is available by writing to: The Data Protection Officer, Money Lowdown, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE; or by email to: hello @ sableedge.digital; As with all your data you can also object to us processing your data in this way. Your rights are detailed below.

4 What categories of personal data do we collect and share?

Personal data means any information that can be used to identify directly or indirectly a specific individual. When registering for our newsletter we will capture your email address. No other personal information will be captured.

We will never collect special category data including medical history, religious or political beliefs and nor will we collect information such as your bank account or credit card details. You always have the right to refuse to answer any question.

5 Who we share your data with?

We will not share your date with any other companies.

6 Communications

Once you are register with Money Lowdown you will receive our regular newsletters including investment news, tips, information and offers. You have a right to object to such processing see below.

There is information on how you can un-subscribe at the bottom of every email that Money Lowdown sends out. We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes when we ask for this information.

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us, we offer an opportunity to opt-out of certain communications on our unsubscribe page: https://moneylowdown.com/unsubscribe/ you may contact us at Money Lowdown, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE.

7 What is Profiling?

Profiling enables organisations to better understand who their customers are so they can make their marketing communications more relevant.

We use some of the information you provide to match with our clients data so that they will better understand the characteristics of their customers. This only happens when you are both on Money Lowdown database and you are a customer of our client. We do not give them specific information about you but we will tell them how many of the customers are on our database. We also help identify whether or not you have similar attributes to a typical customer of our client so they can target you with offers of goods and services tailored to you. We will never profile you on the basis of ethnicity, religion, politics or health as these are not valid reasons for which you should be targeted for marketing purposes and nor do we collect this information. We also do not make automated decisions about you which have a negative impact on your rights. Marketing Services Providers we share your data with can also use profiling to target you for marketing purposes. Once again you can ask us to stop using your data in this way at any time.

8 Do we transfer your data to other countries?

We do not transfer your data to other countries.

9 How long will we keep your data for?

We take your data privacy rights seriously. Whilst the law does not put a time limit on the amount of time we should hold your personal data, Money Lowdown only wishes to retain data for as long as it is required for the purposes for which it was collected; for as long as it remains accurate and up-to-date; and most importantly, for as long as long as you are happy for us to do so.

In addition, to help Money Lowdown maintain the most recent indication of your marketing and data processing preferences, we will provide you with ongoing reminders of your data subject rights with access to this privacy policy. We refer to this as engagement or notification recency. Therefore, our data retention policy considers the purpose, the legal basis under which it is processed and also the most recent engagement.

• Marketing – where we process your data under consent, we will stop using it for marketing purposes after five years. Where we rely on legitimate interests, we will continue to process your data for ten years, subject to receiving notification from ourselves that we hold your information.
• Profiling – we will stop using your data for this purpose after ten years.
• Tracing and Credit Reference – as this purpose plays an important function of protecting individuals, we will retain your data for twenty years. However, only basic name, date of birth and contact information is retained for this purpose.

It is important that the personal data we hold and process is accurate and up-to-date. Therefore, we regularly refresh the database against suppression lists and remove those who no longer wish to be contacted. As we explain in the section marked What are your rights? you can withdraw your consent to us at any time.

10 What are your rights?

You have a number of rights under the law which include;

1. Right to be informed – When we collect your data we have to tell you what we are going to do with it primarily through this Privacy Policy and consent statement.
2. Right of access – You have the right to contact us verbally or in writing to request details of the information we hold about you.
3. Right of rectification – You have the right to ask us to rectify information that we hold about you if it is inaccurate or incomplete.
4. Right to erasure – This is also known as the right to be forgotten and gives you the right to request your information be removed if there is no compelling reason for its continued processing. A word of warning though we keep a list of people who have asked not to be contacted which we use to ensure that you receive no further marketing from our group or clients as a result of our activity. Without this list your data could enter our system again from another source and we would have no record of the fact that you asked us not to contact you.
5. Right to restrict processing – this is the alternative to erasure and gives you the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are respected in the future.
6. Right to data portability – this gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly used if you were switching banks, insurance companies, utilities companies and mobile phone providers.
7. Right to object – you have the right to object to the processing of your data for marketing purposes and profiling for marketing purposes. You also have the right to ask us to cease processing based on our legitimate interests, where there is no overriding justification for the processing of your data. Your rights and freedoms override our interests.
8. Rights related to automated decision making including profiling – we do not use automated decision making processes which would have a potentially damaging effect on you. But if we did you have the right to obtain human intervention, express your point of view, obtain an explanation of the decision and challenge it.
9. Right to withdraw consent at any time where relevant – you have the right to withdraw your consent to the processing of your information at any time and we must provide you with the information to need to do so, at the time we collect your data and each time we contact you. You can withdraw consent in the following ways; In writing to: The Data Protection Officer, Money Lowdown Ltd, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE, or by email to: hello @ sableedge.digital
10. Right to lodge a complaint with a supervisory authority – If we cannot deal with your complaint to your satisfaction you also have the right to complain to a relevant supervisory authority which include; The Information Commissioners Office; Wycliffe House, Water Lane, Wilmslow, SK9 5AF, or call: 0303 123 1113 or online at https://ico.org.uk/concerns/ and The Advertising Standards Authority – https://www.asa.org.uk/make-a-complaint.html

11 Do we collect data from other sources?

In order to keep consumer records as up to date as possible we use third party products to help us verify and suppress data. We use a product called Experian QAS, supplied by Experian PLC, which uses the Electoral Roll and details given by multiple companies to collate and re-verify consumer information. We also match your data against industry suppression files; Telephone Preference Service (TPS) and Mailing Preference Service (MPS). Managed by the Direct Marketing Association (UK) Ltd, these are central registers of individual’s who do not wish to receive unsolicited marketing calls or direct mail. You can register for these free of charge at www.tpsonline.org.uk and www.mpsonline.org. We also occasionally use the National Change of Address (NCOA®) which uses information taken directly from the redirection application forms of people who are moving. When we do collect information from third parties we always check that they have a valid legal basis to process and share your data with us.

We will also use 3rd parties to supply data subjects personal information to us this includes when data controllers supply us with information where you have completed a survey either online or by telephone where an Money Lowdown brand is named on the controller’s privacy policy as a company with whom they share information.

12 When do you have to share my data?

On rare occasions we will be asked to share your information for the prevention of fraud or with regulatory bodies who are investigating complaint made by a consumer.