1. Acceptance of Terms
Boshhh Ltd respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how your personal information is collected, used, and shared when you visit or make a purchase from Boshhh Ltd at boshhh.com (the “Site”).
The Site is not intended for children, and we do not knowingly collect data from children.
Please read this Privacy Policy along with any other privacy or fair processing notices we provide on specific occasions when we are collecting or processing personal data about you. This will ensure you are fully aware of how and why we are using your data. Boshhh Ltd is the controller responsible for your personal data (referred to as “Boshhh Ltd”, “we”, “us”, or “our” in this Privacy Policy).
2. Personal information we collect
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including debit card, email address, and phone number). We refer to this information as “Order Information”. When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.
3. How do we use your personal information?
We use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
- to screen our orders for potential risk or fraud; and
- when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
- when in line with the preferences you have shared with us, to provide you with information or advertising relating to our products or services; and
- in accordance with clauses 4.5 to 4.7 of our Terms & Conditions of Prepay Mobile Services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
4. Sharing your personal information
We share your personal data with credit reference agencies (e.g, Equifax https://www.equifax.co.uk/crain), and fraud prevention agencies (e.g. CIFAS) for use in automated credit decisions, for the detection and protection against crimes such as fraud and money laundering, for identity check purposes (GBG) and for debt recovery purposes, as further explained below. Where we carry out a credit check with a credit reference agency, the information that we give them (including details of your credit application and financial details) and the details of the search itself will be recorded by that credit reference agency. We also exchange information with credit reference agencies on payment performance under your credit agreement on an ongoing basis and this information could be used by us and third parties to make future credit assessment decisions.
As part of your credit check, the credit reference agency may also review information in relation to individuals who are financially linked to the primary applicant. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place. Where appropriate, we may also share your data with other organisations to assist with the prevention and detection of fraud.
We may share your personal data with debt collection agencies where there is an outstanding debt owed on the account. We do this so that they can use the information, alongside other information that they hold, to attempt to contact you on our behalf so that we can recover the debt. In some cases, where we have been unable to recover the amount owed, we may sell the debt to a third-party debt management company. You will be informed when this takes place and following the sale of the debt, any questions you have about communications you receive should be directed to the company in question. We may share your Personal Information to comply with applicable laws and regulations, to respond to other lawful requests for information we receive, or to otherwise protect our rights.
5. Credit reference agencies
If you register to use our services we will obtain on your behalf, in accordance with our Terms, copies of your credit report and credit score from designated
Credit Reference Agencies. In order to provide these services to you, we will share your information with such Credit Reference Agencies.
The information which we provide to the CRA may be supplied by them to other organisations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRA may also use the data to undertake statistical analysis.
If you choose to apply for a product, the lender will undertake a full credit check and provide you with further privacy information for that product. More information about each CRA and what it does with personal data is available here.
6. Behavioural advertising
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://help.ads.microsoft.com/#apex/3/en-us/51029
You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://myadcenter.google.com/home?hl=en
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info
7. Do not track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. International transfers
We do not transfer your personal data outside the UK.
10. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly.
For more information about the cookies we use, please see our Cookies Policy.
11. Your legal rights
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in the circumstances described.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
12. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
13. Changes
We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
14. Third-party links
The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
15. Contact us
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by using the details provided below:
Cardinal House,
20 St Mary’s Parsonage,
Manchester ,
M3 2LY,
England
Tel: 03333 4444 15
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues www.ico.org.uk. We would, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using one of the methods described above.
