This Privacy Policy helps you understand what Personal data We collect, why We collect it, what We do with it and the choices you have, including how to access and update information.

This Website is operated by RedBrain Ltd. and is a trading name of RedBrain Ltd. RedBrain runs a number of product search/comparison Websites that it makes available to the public, and also provides online advertising services to other businesses.
This privacy policy sets out how RedBrain Ltd (collectively referred to as ‘RedBrain Ltd’, ‘We’, ‘us’ or ‘our’ in this privacy policy) uses and protects any information that you give RedBrain Ltd when you use this Website, our products or services. RedBrain Ltd is committed to ensuring that your privacy is protected.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy We may provide on specific occasions when We are collecting, or processing, personal data about you, so that you are fully aware of how and why We are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

RedBrain Ltd may change 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. This policy is effective from 1 May 2020. If We make any material changes to this privacy policy We may notify you by email or via a notice on our Website.

Who We are

RedBrain Ltd is the controller and is responsible for your personal data. If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Email address: privacy@redbrain.com
Postal address: Dorna House Two, 52 Guildford Road, West End, Surrey, GU24 9PW
Telephone number: +44 1276 452260
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

What We collect

We collect personal data about the following two types of individuals:

Members of the public who use our Websites to search for products and services they are looking to buy (‘Website users’); and
points of contact at our corporate clients (‘corporate contacts’), who We engage with in the course of providing our online advertising products and services to our clients. These points of contact are generally employed by, or contracted to our corporate clients.

Website Users

We may collect Website users’ name and email address if they set up an account with our Website. Website users may do this if they wish to use our Website to compare prices of specific products they are searching for. We will also collect information about products and services Website users like, if they create a ‘wish list’ through our Website. If they ask us to, We may send Website users emails when the prices of products or services they like are reduced.

Corporate Contacts

We may collect the following information about our corporate contacts:

  • Name and job title;
  • Contact information including email address;
  • Demographic information such as postcode, preferences and interests; and
  • Other information relevant to customer surveys and/or offers.

Other information We collect

We will collect this information during the course of providing our products and services to our clients, and will collect it either directly from the individual, or our client, the individual’s employer.

We also collect, use and share aggregated data such as statistical or demographic data (‘Aggregated Data’) for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, We may aggregate data about how you use our products and services to calculate the percentage of users accessing a specific feature. however, if We combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, We treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any ‘Special Categories of Personal Data’ about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do We collect any information about criminal convictions and offences.

Where We need to collect personal data by law, or under the terms of a contract We have with you, and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with you (for example, to provide you with our products or services). In this case, We may have to cancel a product or service you have with us, but We will notify you if this is the case at the time.

What do We do with the information We gather

Website Users

We will use Website users’ information in the following ways:

We will use the information Website users provide us when creating their user account in order to set up and administer their account with our Website. Our lawful basis for this processing is our legitimate interest in using the information Website users provide to us to set up and manage their account efficiently, so that they can use the services provided by our Website.

We will hold information about the products and services that Website users are interested in on their ‘wish list’. Our lawful basis for this processing is our legitimate interest in assisting Website users in holding information about their desired products and services, for their future reference when using our Website.
We will use Website users’ contact details and product preferences in order to update them by email when the price of their desired products and services is reduced. Our lawful basis for this processing is the Website users’ consent.

Corporate Contacts

We require the information set out above to understand your needs and provide you with a better service, and in particular for the following reasons:
Internal record keeping. Our lawful basis for this processing is our legitimate interests in keeping appropriate records of our interactions with our clients and the transactions We enter into.

We may use the information to improve our products and services. Our lawful basis for this processing is our legitimate interests in improving our products and services.
We may periodically send promotional emails about new products, special offers or other information which We think you may find interesting using the email address which you have provided. You will receive such marketing communications from us if you have requested information from us (in which case our lawful basis is your consent), purchased products or services from us and you have not opted out of receiving that marketing (in which case our lawful basis is our legitimate interests in marketing and growing our business), or you are a corporate body such as a company or a limited liability partnership (in which case our lawful basis is our legitimate interests in marketing and growing our business).

From time to time, We may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the Website, our products and services according to your interests. Our lawful basis for this processing is our legitimate interests in using the results of such research to inform our business decisions and strategy, and to improve our products and services.
We will only use your personal data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If We need to use your personal data for an unrelated purpose, We will notify you and We will explain the legal basis which allows us to do so.
Please note that We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data Transfers

We may share your personal data with the parties set out below for the purposes set out above.

Service providers acting as processors based in the UK, EU and the USA who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Third parties to whom We may choose to sell, transfer or merge parts of our business or our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever We transfer your personal data out of the EEA, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where We use certain service providers, We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where We use providers based in the US, We may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared betWeen Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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.
By law We have to keep basic information about our customers for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances We will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information We collect.

How We use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse Web traffic or lets you know when you visit a particular site. Cookies allow Web applications to respond to you as an individual. The Web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about Web page traffic and improve our Website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website.

Links to other Websites

Our Website may contain links to other Websites of interest. however, once you have used these links to leave our site, you should note that We do not have any control over that other Website. Therefore, We cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the Website in question.

Rights in respect of your personal information

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

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.

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 personal 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.

If you wish to exercise any of the rights set out above, please contact us using the details set out above.

No fee usually required

You will not 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 these circumstances.

What We may need from you

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.

What We may need from you

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.

What We may need from you

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.