Last Updated: 1st September 2023.

XtraPension Ltd ("XtraPension," "we," "us," or "our") is committed to protecting your privacy and safeguarding your personal information. This privacy policy sets out how XtraPension uses and protects any information you give when you use this website. XtraPension is fully committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy policy. XtraPension may occasionally amend this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

Please read this Privacy Policy carefully, in conjunction with our Terms and Conditions. Unless otherwise defined, terms used here have the same meaning as in our Terms and Conditions. If you have any questions, comments, or complaints about this Privacy Policy, please contact us using the details provided below. By using our Services, you consent to the collection, use, storage, disclosure, and protection of your personal information as described in this Privacy Policy.

WHAT INFORMATION WE COLLECT

• We may collect the following personal information from you:
  • Contact Information such as your name, email address, phone number, and other information you choose to provide
  • Financial and Personal Identifiable Information relevant to determining your eligibility to pay voluntary National Insurance contributions (NICs) in order to claim a UK state pension.
• We may automatically collect information about your use of our services, such as your IP address, device information, browser type, pages visited, and other usage data. This information helps us analyse trends, administer the services, improve user experience, and gather demographic information for aggregate use.
• When customers contact our customer support or engage in communication with us, we may collect and store the content of those communications to address inquiries, provide assistance, and improve our services.

WHAT INFORMATION WE COLLECT

We require this information to understand your circumstances, to provide you with a better service and in particular for the following reasons:

• To administer your account
• To send you periodical application progress updates and promotional communications, such as emails and SMS text messages. You can manage your communication preferences by adjusting your account settings or following the opt-out instructions provided in our communications.
• To provide the service you have requested and notify you about changes to our services
• To provide the service you have requested and notify you about changes to our services.· We may share your contact details with regulated financial partners who offer financial products relevant to your circumstances if you have opted in to occasionally receive such offers.
• We may use the information to analyse usage patterns and improve the quality of our products and services
• To respond to your inquiries and provide customer support.
• To comply with legal obligations, respond to lawful requests or court orders, and enforce our terms and conditions. This includes protecting our rights, safety, and property, as well as the rights, safety, and property of our users or any other third parties.
• We may aggregate and anonymize your information to create statistical or aggregated data that does not personally identify you. This aggregated and anonymized data may be used for various purposes, such as analysing usage patterns, improving our services, conducting market research, or sharing with third parties for lawful purposes.

In addition to the purposes described above, we may use and process your information for any other purposes disclosed to you at the time of collection or with your consent.

CHOICE/OPT-OUT

You may choose to stop receiving any marketing emails/SMS texts by following the unsubscribe instructions included in these emails.

DISCLOSURE OF YOUR INFORMATION

• We may share your information with third-party service providers who perform various functions necessary for the processing of determining your eligibility to pay voluntary NICs or to facilitate your application. These service providers are contractually obligated to handle your data with the utmost confidentiality and adhere to privacy and security standards.
• To ensure compliance with applicable laws, regulations, or legal requirements, we may be required to disclose your personal information to relevant authorities or entities.
• In certain cases, we may disclose your information if we believe that such disclosure is necessary to protect our rights, your safety, the safety of others, or to investigate or respond to alleged or actual legal claims or violations.
• As our business evolves, we may transfer or assign your information in connection with any merger, sale of our assets, or any other change in control of the XtraPension entity. In such cases, your data will remain protected in accordance with this Privacy Policy.
• We may also share aggregated and anonymized data that does not personally identify you with third parties for various purposes. This may include sharing statistical information, usage patterns, or demographic data for research, analytics, marketing, or other lawful purposes.

LEGAL BASIS FOR PROCESSING YOUR DATA

XtraPension processes your personal data for a variety of purposes, each of which must have a legal basis. Our legal basis for collecting, using, and processing your information may vary depending on the specific context and the nature of the information.

• When you use our services or provide us with your personal information, you may be asked to give your explicit consent to the processing of that data. You have the right to withdraw your consent at any time.
• We may need to process your data to fulfil a contract or agreement we have with you. For example, when you apply for our services, we require certain data to process your application and provide our services to you.
• Some processing may be necessary to comply with legal obligations. This includes situations where we are required to disclose your data to authorities in compliance with legal and regulatory requirements. Processing your data may also be necessary for the establishment, exercise, or defence of legal claims.
• We may process your data when it is in our legitimate interests and does not override your rights and interests. These interests may include improving our services, maintaining the security of our systems, conducting research and analysis, sending you marketing or promotional communications including cold e-mails or complying with legal requirements.
• We may process your data when it is required to perform a task carried out in the public interest or in the exercise of official authority.

We process your data in compliance with applicable data protection laws and will always have a valid legal basis for doing so. If you have questions about the specific legal basis on which we process your data, please contact us.

UPDATING, VERIFYING AND DELETING PERSONAL DATA

You may inform us of any changes in your Personal Data, and in accordance with our obligations under the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”).We will update or delete your Personal Data accordingly. You can update us via our website.

TRANSFER OF DATA

The General Data Protection Regulation (GDPR) and other data protection laws may require additional safeguards when transferring personal data from one jurisdiction to another, especially to a jurisdiction outside the European Economic Area (EEA) or any other region with data protection laws that may differ from those in your jurisdiction. By using our services and submitting your personal data, you consent to the transfer of your data to United Kingdom and its processing there. We are committed to protecting your personal data, and we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, as well as any applicable data protection laws, including the Australian Privacy Act and the GDPR. This may involve using standard contractual clauses or other approved mechanisms to provide adequate safeguards for international data transfers. Your consent to this Privacy Policy, coupled with the submission of your information, indicates your agreement to this data transfer and processing, including to jurisdictions outside the EEA.

DATA SECURITY

At XtraPension, we are committed to ensuring the security of your data. We implement a range of technical and organizational measures to safeguard your data..

• Secure Data Storage: Your personal data is securely stored on our servers, and we take steps to ensure that these servers are protected against unauthorized access and breaches.
• Encryption: All data transmissions between your device and our servers use secure encryption protocols to prevent interception.
• Access Control: Access to your data is restricted to authorized personnel who require access to perform their job duties. They are bound by confidentiality obligations.
• Data Retention: We retain your data for only as long as necessary for the purposes specified in our Privacy Policy and in compliance with UK data protection laws.
• Regular Audits: We conduct regular security audits and assessments to identify and address vulnerabilities.
• Data Minimization: We collect and process only the data that is necessary for the specific purposes for which it was obtained.
• Data Breach Response: In the event of a data breach, we follow applicable legal requirements for reporting breaches and inform affected individuals as necessary.

Our commitment to data security aligns with UK regulations, including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

YOUR RIGHTS AND CHOICES

Our commitment to data security aligns with UK regulations, including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

• Right to Access and Rectification: You have the right to request access to the personal information we hold about you and to correct any inaccuracies.
• Right to Erasure: You have the right to request the deletion of your personal information under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent and there is no other legal basis for processing.
• Right to Restrict Processing: You have the right to request the restriction of processing of your personal information under certain circumstances, such as when you contest the accuracy of the data or when the processing is unlawful.
• Right to Data Portability: If you reside in a jurisdiction that provides for data portability rights, you may have the right to receive a copy of your personal information in a commonly used and machine-readable format and to transmit it to another data controller.
• Right to Object: You have the right to object to the processing of your personal information on grounds relating to your particular situation, including for direct marketing purposes. If you have provided your consent to receive marketing communications from us, you can opt-out at any time by following the instructions provided in the communications.
• Withdrawal of Consent: If you have provided your consent for the processing of your personal information, you have the right to withdraw your consent at any time. Please note that the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of your rights described in this section, or if you have any questions or concerns about our data practices, please contact us using the contact details provided in the "Contact Information" section of this Privacy Policy. We will respond to your request and address your concerns in a reasonably timely manner and in accordance with applicable data protection laws. We request that you contact us first before lodging any complaints to the relevant data protection authorities.

OTHER PERSONALISED AND BEHAVIOURAL ADVERTISING SERVICES

We may participate in additional retargeting and behavioural advertising services. You can control the placement of cookies and other data collection methodologies by opting out.

COLD EMAIL CAMPAIGNS

Collection of Information: We may collect the following information for the purpose of sending you relevant and targeted cold emails. This information is sourced directly from publicly available sources, including the internet, industry-specific directories, or other reliable sources:

• Contact Information: This includes your full names and email address.
• Tracking Information: We may use tracking technologies to understand how you interact with our cold emails, such as open rates, click-through rates, and the time you interact with our emails.

Use of Information: We use the information collected through cold emails for the following purposes:

• To send you relevant content, updates, or promotional materials.
• To track the performance of our cold email campaigns and make data-driven improvements.
• To discuss potential business opportunities, partnerships, or collaborations, but only in connection with business-related matters and never personal matters. We do not hold or store any information which could identify you outside your ordinary place of business.
• To ensure that our communications and services remain relevant to our corporate subscribers.

Sharing and Disclosure: We may use third-party email marketing service providers to send our cold emails. These service providers are required to adhere to our privacy and security standards.

Your Rights: You have the right to:

• Opt-Out: You can unsubscribe from our cold email communications at any time by using the "unsubscribe" link provided in the email.
• Access, Correct, or Delete: You can request access to the personal information we hold about you and update or delete it as needed.

Data Retention: We do not retain this information longer than is required for the purposes for which it was collected or as permitted under applicable law. Should we fail to engage you or our engagement ceases for whatever reason then it is our policy to delete your information after 12 months.

Consent: For information obtained from external sources, we may not require your explicit consent to process this data. The processing of this information aligns with our legal basis for processing and aligns with your interest in exploring business opportunities and maintaining the relevance of our services.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also helps us to improve our website. For more information on cookies, please see our cookie policy.

USER TESTIMONIALS

We value feedback from our users, and occasionally, we may showcase user testimonials on our websites and materials. If a user has shared personal information in their testimonial, rest assured that we have obtained the necessary consent to feature it. Your privacy is of utmost importance to us, and we only share user testimonials with the express permission of the individuals involved unless they have been published directly on 3rd party platforms such as Google, Meta or Linkedin etc. If you have any questions or concerns regarding the use of your testimonial or personal information, please don't hesitate to contact us.

NOTIFICATION OF CHANGES

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address you have provided previously) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT US

Any queries may be directed to our Data Protection Officer:
Slaier
support [at] xtrapension.com

You can also contact us by writing or email us at the address below:
XtraPension Ltd
Gray Office Park
H91 C3N1
Ireland
Phone: +353 (0)91 123 456