Privacy policy

 

We are committed to protecting your privacy

Close Brothers Military Services provide the services and content available on Closebrothersmilitaryservices.com (together or individually referred to as “the Site”), and are committed to protecting and respecting your privacy. This policy (together with the terms of use and any other documents referred to in it) sets out the basis on which any personal data Close Brothers Military Services collect from Users, or that Users provide to Close Brothers Military Services will be processed by it. Please read the following carefully to understand Close Brothers Military Services’ views and practices regarding your personal data and how it will treat it. For the purpose of the Data Protection Act 1998 (“the Act”), the data controller is Close Brothers Limited of 10 Crown Place, London, EC2A 4FT with registration number Z5313910.

Information Close Brothers Military Services may collect about Users

This policy applies to all information Close Brothers Military Services receives from you, whether you are registering on our website or ordering any of our products. During the course of your use of this website, Close Brothers Military Services may collect two types of information:

1. Website Usage Information – This website uses Google Analytics to automatically gather certain statistical information such as the number and frequency of visitors and IP addresses. This information is used as aggregated statistical information about users, providing usage by IP address. Individual users cannot be identified from this type of data. This information helps us to measure how individuals use the website and our services, so that we can continually improve them.

2. Personal Information – Close Brothers Military Services requires personal information from you, such as name, e-mail address, telephone numbers, fax numbers and credit card data in order for us to perform the services offered by the site and to fulfil your requests. Some of this information is voluntary; the compulsory fields are clearly identified whenever you are asked to supply information. On occasions, Close Brothers Military Services may also collect additional information from you on a voluntary basis.

We obtain personal information that is needed to provide our goods and services and respond to enquiries.

When Close Brothers Military Services collects information directly from individuals, we obtain the personal information that is needed to provide our goods or services, respond to enquiries, to provide customer service and to fulfil any legal or regulatory requirements. We also obtain personal information as a result of individual’s financial transactions with Close Brothers Military Services or with Close Brothers Military Services business customers. When we obtain information about individuals from third parties, we use reputable sources, including public repositories. Close Brothers Military Services employs appropriate measures to assure the quality of information which we collect.

This personal information may be used in a number of ways:

  • Information that Users provide by filling in forms on the Site. This includes information provided at the time of registering to use any part of the Site, subscribing to any service, posting material or requesting further services. Close Brothers Military Services may also ask Users for information if (for example) Users report a problem with the Site.
  • If Users contact Close Brothers Military Services, Close Brothers Military Services may keep a record of that correspondence.
  • Details of any transactions Users carry out through the Site and of the fulfilment of any orders.
  • Details of Users' visits to the Site including, but not limited to, the referrer page, the pages of the Site accessed, traffic data, location data, weblogs and other communication data, along with the time of these events.
  • Recordings and location data of any phone calls Users make to Close Brothers Military Services, for regulatory purposes, in order to monitor our quality of service, or to establish facts.
  • Identifying potential new customers and subscribers.
  • Detecting and preventing fraudulent activity.
  • Detecting and preventing money laundering activity.
  • As part of the account opening process for new customers, to verify your identity.
  • We may also use the information for making a credit check on you and may share it with third parties to protect ourselves against fraud. We may carry out a search with a Credit Reference Agency who will keep a record of our enquiry against your name. We may use a credit scoring or other automated decision making system when assessing your application. Details of which credit reference agency we have used are available on request.
  • Providing you with the service that you have requested.
  • We may from time to time contact you to conduct market research for regulatory purposes, in order to monitor the quality of the products and services we provide.
  • We may also contact you via post, e-mail or telephone in relation to the administration of your account or to provide a service you have requested or carry out quality control research.
  • We may access and disclose personal information about you if you breach this privacy policy, and / or fail to comply with applicable laws, court orders and lawful government requests, to operate our systems properly or to protect ourselves and/ or our other users.
  • We take all reasonable precautions to ensure that outside parties or affiliated companies are aware of our privacy policy and that they will treat the personally identifiable information in a similar manner. We cannot, however, be responsible for how such outside parties or affiliated companies use your personal information.

We are committed to protecting the confidentiality of personal consumer information

Within Close Brothers Military Services, access to personal information is limited to those employees of Close Brothers Military Services and its affiliates who need it to fulfil their business responsibilities. Vendors and other outside contractors we engage are subject to contractual requirements to ensure personal information is safeguarded. We will disclose personal information in response to a lawful request issued by a court, government agency or regulatory authority with jurisdiction to make that request.

IP addresses

Close Brothers Military Services may collect information about Users' computers, including where available their IP address, operating system and browser type, for system administration.

Where Close Brothers Military Services store your personal data

All information Users provide to Close Brothers Military Services is stored on Close Brothers Military Services’ secure servers in the UK.

Unfortunately, the transmission of information via the internet is not completely secure. Although Close Brothers Military Services will do its best to keep confidential and protect your personal data, Close Brothers Military Services cannot guarantee the security of Users' data transmitted to the Site; any transmission is Users' own risk. Once Close Brothers Military Services has received Users' information, Close Brothers Military Services will use strict procedures and security features to try to prevent unauthorised access.

Close Brothers Military Services is committed to implementing the highest standards of information security to protect the privacy and confidentiality of your personal information. We limit access to your personal information to authorised Close Brothers Military Services employees. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorised access or disclosure.

Uses made of the information

When we have a direct relationship with individuals, we will strive to make information available to them about the general uses of the information that we collect. This information is made available at the point of sale, through privacy notices on our websites, in other formats that are publicly available or through other means specified by applicable EU legislation and laws.

Close Brothers Military Services use information held about Users in the following ways:

  1. To ensure that content from the Site is presented in the most effective manner for Users and User’s computer;
  2. To provide Users with information, products or services that they may request from Close Brothers Military Services or which Close Brothers Military Services feels may interest Users, where they have consented to be contacted for such purposes;
  3. To carry out Close Brothers Military Services obligations arising from any contracts entered into between Users and Close Brothers Military Services;
  4. Share information with Close Brothers Group.
  5. To allow Users to participate in interactive features of the service, when Users choose to do so; and
  6. To notify Users about changes to the Site.
  7. To compile market research regarding the quality of the products and services we provide to customers for regulatory purposes
  8. Where Users' data is used to provide Users with information about goods and services which may be of interest, Close Brothers Military Services will contact Users by electronic means only if they have consented to this.

Disclosure of your information

Close Brothers Military Services may disclose your information to other business areas within the Close Brothers Group, our affiliates, associates or closely linked persons (howsoever defined by law or regulation), their directors, officers, employees and agents as well as any government entity or third party, for the purpose(s) outlined above or as a matter of law. Close Brothers Military Services may disclose your personal information to third parties: in the event that Close Brothers Military Services sell or buy any business or assets, in which case Close Brothers Military Services may disclose your personal data to the prospective seller or buyer of such business or assets; if Close Brothers Military Services or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and/or if Close Brothers Military Services are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the terms of use and other agreements; or to protect the rights, property, or safety of Close Brothers Military Services, its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Your rights

Users have the right to ask Close Brothers Military Services not to process their personal data for marketing purposes. Close Brothers Military Services will usually inform Users if it intends to use their data for such purposes or if it intends to disclose their information to any third party for such purposes. Users can exercise their right to prevent such processing by contacting Close Brothers Military Services, North Wing, Park House, Peterborough Business Park, Lynch Wood, Peterborough, PE2 6FZ. The Site may, from time to time, contain links to and from the websites of Close Brothers Military Services’ partner networks, advertisers and affiliates. If Users follow a link to any of these websites, they should note that these websites have their own privacy policies and that Close Brothers Military Services does not accept any responsibility or liability for these policies. Users should check these policies before they submit any personal data to these websites.

Visitors under the age of 16

Close Brothers Military Services do not intentionally collect personally identifiable information online from a child under 16 since the Site is not directed at children. Any Users under 16 must get approval from a parent/guardian prior to submitting information. Users without consent are not allowed to provide us with information.

Access to information

The Act gives Users the right to access information held about them. User’s right of access can be exercised in accordance with the Act. If Users would like a copy of some or all of their personal information they should email enquiries@close.uk.com, or write to Close Brothers Military Services at North Wing, Park House, Peterborough Business Park, Lynch Wood, Peterborough, PE2 6FZ. Any access request may be subject to a fee to meet Close Brothers Military Services’ costs in providing Users with details of the information it holds about them.

If you believe that any information we hold about you is incorrect or incomplete, you should write without delay to Close Brothers Military Services, North Wing, Park House, Peterborough Business Park, Lynch Wood, Peterborough, PE2 6FZ. Any information which is found to be incorrect or incomplete will be corrected promptly.

Complaints

All complaints or concerns and appropriate resolution relating to the practices of handling personal information will be logged. Any complaints should be made to Close Brothers Military Services Complaints Department on 01733 372850 or email: enquiries@close.uk.com.

Data Retention

Close Brothers Military Services will retain the information for as long as it is reasonably considers necessary for the purposes listed above. Once we have processed your transaction, we will only retain your full credit card data (encrypted within Close Brothers Military Services secure systems) if you have asked Close Brothers Military Services to do this, to make it easier for you to use the site for repeat purchases.

Use of Cookies

For full details on what cookies are, what they do, and which cookies are used by Close Brothers Military Services, please see our Cookie Policy.
To enable you to sign in and personalise your online experience, Close Brothers Military Services uses “cookies”. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer.

Close Brothers Military Services uses cookies to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalised content and appropriate advertising on your later visits to Close Brothers Military Services website.

Changes to this privacy policy

Due to the rapidly evolving technologies and capabilities on the internet and evolving EU compliance legislation, Close Brothers Military Services may need to change this privacy policy over time. Close Brothers Military Services may revise these terms of use at any time for security, legal, best practice or regulatory reasons by amending this page. Close Brothers Military Services will not use this right to make substantial changes to the terms to Users' detriment without giving Users a chance to agree. Users are expected to check this page from time to time to take notice of any changes Close Brothers Military Services made, as they are binding on Users. However, data taken before any changes will not be affected without your individual permission.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Close Brothers Military Services, North Wing, Park House, Peterborough Business Park, Lynch Wood, Peterborough, PE2 6FZ.