Frednel Commercial Management Services Ltd

customer privacy notice

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• How to complain

Contact details

Post

Frednel Commercial Management Services, 9 Greyfriars Road, READING,
RG1 1NU, GB
Telephone
+44 736 049 6820

Email

info@frednel.com

What information we collect, use, and why

We collect or use the following information to provide and improve  products and services for clients:

• Names and contact details
• Addresses
• Occupation
• Payment details (including card or bank information for transfers and direct debits)
• Transaction data (including details about payments to and from you and details of products and services you have purchased)
• Usage data (including information about how you interact with and use our website, products and services)
• Employment details (including salary, sick pay and length of service)Information relating to compliments or complaints
• Records of meetings and decisions
• Account access information

Website user information

We collect or use the following personal information for the operation of client or customer accounts:

• Names and contact details
• Addresses
• Purchase or service history
• Account information, including registration details
• Information used for security purposes

Marketing preferences

• Names and contact details
• Addresses
• Profile information
• Marketing preferences
• Purchase or account history
• Website and app user journey information
• IP addresses

We collect or use the following personal information for research or archiving purposes:

• Names and contact details
• Addresses
• Purchase or client account history
• Website and app user journey information
• IP addresses

• Contact details (eg name, address, telephone number or personal email address)
• Date of birth
• National Insurance number
• Copies of passports or other photo ID
• Employment history (eg job application, employment references or secondary employment)
• Education history (eg qualifications)
• Right to work information

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Account information
• Purchase or service history
• Call recordings
• Photographs
• Customer or client accounts and records
• Information relating to health and safety (including incident investigation details and reports and accident book records)
• Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting  and using your personal information. There is a list of possible lawful  bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data
protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such
  as details about where we get personal information from and who we share personal information with. There are some exemptions
  which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or
  incomplete. You can read more about this right here.
• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and  in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply,
  except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without
  causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

• We collect personal information based on our legitimate interest to effectively manage customer relationships, provide relevant services and support, improve our products and services, and conduct targeted marketing activities, while ensuring that the processing of this information is balanced against your privacy interests.

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply,
  except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may
  apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without
  causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

• We collect personal information based on our legitimate interest to effectively manage customer relationships, provide relevant services and support, improve our products and services, and conduct targeted marketing activities, while ensuring that the processing of this information is balanced against your privacy interests.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by
  an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply,
  except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may
  apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without
  causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

• We collect personal information based on our legitimate interest to effectively manage customer relationships, provide relevant services and support, improve our products and services, and conduct targeted marketing activities, while ensuring that the processing of this information is balanced against your privacy interests.
• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by
  an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
  Our lawful bases for collecting or using personal information for research or archiving purposes:
• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply,
  except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may
  apply, except the right to erasure, the right to object and the right to data portability.

• We collect personal information based on our legitimate interest to effectively manage customer relationships, provide relevant services and support, improve our products and services, and conduct targeted marketing activities, while ensuring that the processing of this information is balanced against your privacy interests.
• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

• We collect personal information based on our legitimate interest to effectively manage customer relationships, provide relevant services and support, improve our products and services, and conduct targeted marketing activities, while ensuring that the processing of this information is balanced against your privacy interests.
• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

• We collect personal information based on our legitimate interest to effectively manage customer relationships, provide relevant services and support, improve our products and services, and conduct targeted marketing activities, while ensuring that the processing of this information is balanced against your privacy interests.
• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Where we get personal information from

• Directly from you
• Regulatory authorities
• Publicly available sources
• Previous employment
• Market research organisations
• Providers of marketing lists and other personal information
• Suppliers and service providers

How long we keep information

We will retain your personal information for only as long as necessary to fulfill the purposes outlined in this privacy policy, considering the
applicable legal requirements and our business needs. This generally means we will keep your data for the duration of your relationship with
us, plus a reasonable period afterwards to comply with record-keeping obligations, potential legal claims, or for auditing purposes. Once the
retention period is reached, your personal information will be securely deleted or anonymized.

Who we share information with

Others we share personal information with

• Debt collection agencies
• Other financial or fraud investigation authorities
• Professional or legal advisors
• Regulatory authorities
• Organisations we’re legally obliged to share personal information with
• Publicly on our website, social media or other marketing and information media

How to complain

If you have any concerns about our use of your personal data, you can  make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Last updated 23 January 2025