Privacy Policy – Lifestyle Choices

LIFESTYLE CHOICES – PRIVACY POLICY

This Privacy Policy governs the manner in which we collect, use, maintain, and disclose information collected from users (“User” or “you”) of our data processing and generation services (“Services”). This Privacy Policy applies to the Services provided by us.

Who we are:

We are a direct marketing organization called Ekaive Ventures Ltd registered in England and Wales under company registration number 15016193, whose registered office is at 71-75 Shelton Street, London, WC2H 9JQ

We are registered with the ICO under registration number ZB668709.

We collect and process personal data to help organizations better communicate with individuals. We operate under the brand name LIFESTYLE CHOICES and we run marketing surveys on behalf of some of the leading UK brands to help them target their products and services better. We conduct marketing surveys both online and by telephone. When we call you we will always display a valid telephone number to identify us. You are always able to call this number back to stop any future calls if that is your wish.

What categories of personal data do we collect and share:

Personal data means any information that can be used to identify directly or indirectly a specific individual. During the course of completing a marketing survey we collect different types of personal data from you. This data can be categorized into four types:

Demographic – This relates to basic information such as your gender, name, DOB and contact details.
Life stage – This relates to information such as marital status, type of employment, household income and presence of children.
Lifestyle – This relates to your likes and dislikes or your hobbies or your hobbies and interests. E.g. whether you like to travel.
Purchase intent – This relates to things like reducing your household bills or making home improvements.

Special category data is personal data that needs more protection because it might be considered more sensitive or private. We will never collect special category data such as medical history, religious or political beliefs and nor will we collect information such as your bank account or credit card details.

You are never obliged to provide your personal information or complete a marketing survey. If you do decide to complete a marketing survey, you always have the right to refuse to answer any specific question. You can also remove your permission at a later date, see the “What are your rights” section for more detail.

What do we use your data for:

The data that you provide us is for the following purposes:

Direct marketing – We will contact you by email, SMS or telephone to ask you questions for marketing purposes. We also share your details with selected companies who want to contact you by telephone and post to offer you goods and services that we believe will be of benefit to you.
Profiling – We will profile your information for marketing purposes to help our clients deliver marketing communication that is more relevant to you. Profiling analyses aspects of an individual’s lifestyle, behavior, and interests to make predictions on whether you might find our clients offers and products interesting. We will never make automated decisions about you which would have a negative impact on your rights. Our partners may use your data for tailored advertising, measurement of the effectiveness of the advertising and identity resolution.
ID Protection & Tracing – We will also share your details with credit reference and identity verification organizations which help other organizations verify your identify and prevent others from misusing your details.

You can ask us to stop processing or sharing your details at any time now or in the future by emailing at compliance@lifestyle-choices.com or by writing to us at 71-75 Shelton street, London, WC2H 9JQ or online at www.lifestyle-choices.com

What will happen if you share your personal data:

The purpose of this section is to explain what may happen if you share your personal data with us.

Marketing – Marketers do not want to bombard individuals with wasted communication. It is costly, frustrating and can waste everyone’s time. Therefore, sharing your data helps marketers improve how they target their communications better, which in turn helps you obtain access to products and services that may be of interest or may help you to save money – for example, if you tell us that you want to reduce your monthly household bills, the you may be contacted to provide a quote for cheaper energy supply. In short, by sharing your personal data with us you will be more likely to receive marketing that is relevant to you and your interests. It does not mean that you will receive more marketing messages, just more that is suited to you.
Profiling – Personal data can also help organizations better understand their customers. By considering their likes and dislikes and their hobbies and interests they are able to build a clearer picture of their audience, which can then help them develop better and more relevant products and services or target their marketing communication more effectively.
ID Protection & Tracing – Sharing your data with identity tracing and credit reference agencies is for non-marketing purposes. ID protection and tracing helps prevent fraud or helps clients trace individuals for purposes such as asset recovery or asset reunification. Credit reference services promote responsible lending or prevents over-indebtedness.

By sharing your personal data with responsible organizations, you can receive positive benefits, choice and access to relevant offers. When we do share your details, we do so under strict license terms and for specified purposes only. However, you should always ensure that you are provided with a clear and transparent description of how and why your data will be processed. As a data subject you will always remain in control of your data – please refer to the section “What are your rights”.

What legal basis do we use for processing your data:

Your data must be processed by us using one of the valid legal bases defined by the Regulations. When you provide your personal data we process this using two different legal basis depending on the purpose; either consent or legitimate interests. We will never switch from one legal basis to another without your permission. The different purposes are summarized in the table below:

Purpose	For use by ourselves	For use by third parties (our clients)
Marketing – By email	Consent	Consent – but only when you provide specific consent for a named organization.
Marketing – By SMS	Consent	Consent – but only when you provide specific consent for a named organization.
Marketing – telephone	Consent – when your number is registered on the telephone preference service. Legitimate interest – where our number is not registered on the telephone preference service.	Consent – but only when you provide specific consent for a named organization. Legitimate interest – where your number is not registered on the telephone preference service.
Marketing – by post	Legitimate Interest – where you are registered on the mailing preference service we will ask for your specific consent.	Legitimate interest – Where you are registered on the mailing preference service we will ask for your specific consent
Marketing – Online (e.g. via social media)	Legitimate interest	Legitimate interest
Marketing – by TV	Legitimate interest	Legitimate interest
Tracing, ID verification and credit reference	Legitimate interest	Legitimate interest
Profiling and analytics	Legitimate interest	Legitimate interest
Service messaging – by email	Legitimate interest	Contract/Legitimate interest
Service messaging – by post and email	Legitimate interest	Contract/Legitimate interest

Consent:

In short this is where you consent to a specific organization, to contact you by a specific communication channel(s) for a specific reason, which in the context of our processing will be for marketing purposes. When we ask for your consent, we will do so by giving you the opportunity to tick a box online or answer a question on the phone. You can of course withdraw your consent at any time and we will describe how later on in this policy.

Examples of where we use consent:

We obtain consent for our brand (lifestyle choices) to contact you by telephone where your number is registered on the telephone preference service (TPS) or by email an SMS.
To pass your contact details to named third parties where your number is registered on the telephone preference service (TPS) or by email and SMS.
To pass your contact details to named third parties where Privacy and Electronic Communications Regulation (PECR) applies sch as email marketing, SMS marketing or where your telephone number is registered with the TPS.
To pass your contact details to named third parties where your postal address is registered with the mailing preference service (MPS).
Where our client has specifically asked us to gain your consent to pass on your details.
Where our client has specifically asked us to gain your consent to pass on your details.
All cookies & similar technologies which do not meet the “strictly necessary” exemption under PECR.

When we obtain your consent, we will explain who the consent is for (e.g. which brand or organization), how you will be contacted (e.g. by email or by telephone) and why (e.g. to provide a cheaper quote). We will provide your information to the brand or organization who can only use your personal information for the purposes that you have provided your consent for. You are able to withdraw your consent at any time. See the section What are your rights? For further information.

Legitimate Interest:

As a direct marketing organization we process personal information for various legitimate business purposes which include some or all of the following:

To help make the communication more relevant
To provide direct marketing communications which we think will be of interest to you
To enhance our services for the benefit of our clients including verification and validation
To better understand how our clients interact with our services
To determine the effectiveness of our and our clients’ promotional campaigns
To indentify and prevent fraud

These legitimate business purposes relate to the following activities:

Direct Marketing – Postal and telephone marketing by both Ekaive Ventures and its brands (including Lifestyle Choices and other third parties) but in either case communication will be in relation to products or services which we believe are of interest to you based upon information which you have provided us.
Social Media Advertising – Using data provided by you to serve advertising to you on social media platforms such as Facebook.
Addressable TV Advertising – A form of television advertising where advertisers are able to target video adverts to specific households during scheduled TV programmes. Relevant advertisements are then shown while you are watching TV either on-demand, live-streaming or traditional television viewing.
Profiling – we will profile your information for marketing purposes to help our clients deliver marketing communication that is more relevant to you (for more information, please refer to the profiling section)

We also share anonymized data with third parties that we collaborate with to optimize campaign performance and display online adverts to you. The personal information is hashed using the latest and most secure technology, hashing refers to the process of transforming data to a combination of numbers and letters which cannot be recognized or decoded so it is not considered personal data as it has been anonymised.

We also collect information when you visit our site using cookies and similar technologies. Should you prefer not to share such information, you can select your preferred options on this website by selecting the “Cookie Settings” shown at the bottom left-hand corner of this site.

ID Protection & Tracing – This is in relation to appropriate agencies which we have listed below which could help protect your identity and prevent fraud.

We process your data in the following ways:

To pass on your personal information to our clients for marketing purposes who will send postal marketing to you, (except where you are registered with the MPS) or contact you by telephone (except where you are registered with the TPS). Marketing will only ever be from organisations operating within the industry sectors described below.
To call you where your telephone number is not registered on the TPS.
To call you where we have obtained your details from a third party. We will always be named within their privacy policyas a party to whom they share your information; once contact is made we will obtain your consent at the earliest opportunity. You will always be given the option to opt out should you not wish to hear from us again.
To process your personal information for the purposes of customer analysis, non-automated profiling and direct marketing, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
To pass to our clients for use including tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, byt not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti – fraud processes, asset recovery and asset reunification. More information on this can be found in the Credit References and Other Agencies section.
To determine the effectiveness of our clients’ promotional campaigns and advertising, and to develop our products, services, systems and relationships with you.
Processing your information to protect you against fraud when using our website, and to ensure our websites and systems are secure.

To pass on your details to companies to help their clients tailor roducts and services which best suit your needs. They will also use your data for fraud prevention. More information on this can be found in the Marketing Services Providers section.

To pass some of your details to social media platforms such as Facebook and TV advertising platforms to understand if you use that platform. This is known as matching or linkage. If you do use that platform, we may ask it to show you relevant advertising which we think will be of interest to you based on the information you have previously provided us. If your data does not match, the platform will immediately delete it. The platform will typically match based on email address, postal address or IP address. They will act as processor and will not share the Data with third parties or other advertisrs. They will delete the Data promptly after the match process is complete. The platform will maintain the confidentiality and security of the data by maintaining technical and physical safegurards that are designed to (a) protect the security and integrity of data while it is within the platform’s systems and (b) guard against the accidental or unauthorized access, use, alteration or disclosure of data within its systems.

It is important that we keep your details up to date, therefore we use various methods such as Quick Address Systems (QAS) which is a serviceprovided by Experian Ltd, National Change of address which uses information taken directly from the redirection application forms of people who are moving and the Edited Electoral Register (EER) which contains the names and addresses of those voters who have indicated that their details can be used for a purpose other than electoral or statutory use e.g. for direct marketing use by a commercial or other organization. Further information can be found in the section Do we collect data from other sources?

For all types of processing, we apply various measures to carefully protect your privacy rights. In considering the most appropriate legal basis, We conducted Legitimate Interest Assessments. These are detailed evaluations of each type of data processing activity to ensure that we have balanced the need of the processing against the rights of the individual to ensure minimal privacy impact. This documentation is available by writing to: Ekaive Ventures Limited, 71-75 Shelton, London, WC2H 9JQ or by email to : complaince@lifestyle-choices.com;

As with all your data you can also object to us processing your data in this way. Your rights are detailed below.

Who do we share your data with:

A. Our Group of companies and brands
B. Groups of recipients within the specific industry sectors listed
C. Marketing Services Providers
D. Named Clients
E. Credit Reference Agencies

A. Our Group Companies and Brands:

Ekaive Ventures Ltd and its brand Lifestyle Choices is a Data processor working on behalf of data controllers to store, prepare and share data with reputable UK business for marketing purposes. Lifestyle Choices works under instruction of the Data Controllers, such as Ekaive Ventures Ltd, who collect information directly from you. To object to the processing of your information please contact Lifestyle Choices by email at compliance@lifestyle-choices.com

Ekaive Ventures Ltd is a direct marketing co-operative bringing together customer information on behalf of UK retailers. Participating retailers specialize in clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty and household goods. Transactis analyses this information on behalf of the retailers to help them better understand consumers’ interests and wider buying patterns. Marketing communication will only ever be by post.

B. Groups of recipients within specific industry sectors listed below:

Industry Sector	Examples include, but not limited to:
Automotive	e.g., car manufacturers, test drives, servicing, breakdown cover
Charity	e.g., animal welfare, disaster relief, children’s medical, elderly, environmental, health
Gaming	e.g., bingo, betting, competitions, lottery
Leisure	e.g., food & drink, events, museums, cinema
Financial Products	e.g., banking, credit cards, investments, loans, mortgages, debt managements, tax/accountancy services, funeral plans
Insurance	e.g., car, home, life, medical, pet, income protection, travel, warranty products.
Health / Mobility	e.g., fitness, beauty, opticians, hearing, care homes, mobility
Home improvements	e.g., house moving, blinds & curtains, insulation, boilers, conservatories, doors & windows, extensions, gardens, solar panels, home security systems, home appliances and the repair thereof.
Wills	e.g., writing new Wills or reviewing existing Wills
Mail Order	e.g., catalogues, online retailers
Market Research	e.g., to gather information about consumers’ opinions and preferences
Media	e.g., online, television, radio, newspapers, magazines
Retail	e.g., fashion, groceries, electrical goods, comparison sites, discounts, FMCG, nicotine and smoking alternatives
Telecoms	e.g., landline, mobile phones, broadband, digital TV
Travel	e.g., long haul holidays, city breaks, flights, UK breaks, accommodation
Education	e.g., online tutoring, personal development, academic camps.
Utilities	e.g., gas & electricity switching, other household utilities such as water

From time to time, we also supply data to these sectors via agencies/brokers; we ensure that these agencies/brokers are reputable firms. When we share data with organizations by industry sector, we do so using legitimate interests.

C. Marketing Service Providers

are companies who collect data from Data Controllers, such as ourselves, and help their clients tailor products and services which best suit your needs.

We will share your data with the Marketing Services Providers listed below, who will use it for a variety of direct marketing purposes. Marketing Services Providers carry out data profiling. They will combine your data with data they get from other sources to create models to try to predict behavior and preferences (e.g., how likely you are to buy a holiday online or take a particular type of holiday) or likely circumstances (e.g., weather you are eligible for a particular credit card). Marketing Services Providers will also try to match and then link your data with data that they receive about you from other sources, to make sure that the data they hold about you is correct (e.g. to check whether you have recently moved address) or keep the IP address they receive from us might change services provider might find it helpful for this to be refreshed from time to time to ensure marketing messages are being delivered to the correct consumers, on the correct device(s). They share your data, including the profiled data they have created about you, primarily to:

Help organizations better understand the likely characteristics of their customers (and find others like them);
Inprove the relevancy and appropriateness of an organisation’s marketing to its customers (e.g. offers, its products and services); and
Help them communicate with their customers more effectively offine and online. This may mean that you receive tailored advertising via direct mail, when you vidit a website, via a mobile app or watch TV. The marketing service providers will not however advertise their own products or services to you.

We do not share information such as cookies.However, Marketing service providers may link the personal information we share with them to cookies stored on your browser or device, but only if you have already provided the necessary permissions.

In shareing your data with Marketing service providers, we rely on ‘legitimate interest’, as our business depends on our ability to partner with third parties who pricess personal data for marketing – related reasons. To understand more about the use of your data by Marketing Services providers, and to find out how to exercise your data protection rifhts in relation to their use of your data (including how to opt-out), please click through to the websites of the companies below:

Ekaive Appliance Care – appliancecare.ekaive.com/privacy-policy
Lead Intelligence Ltd – get.leadintelligence.co.uk/privacy-cookie-policy

D. Named Clients

In addition to organisations that fall within industry sectors listed in Section B, we also supply data to the following clients who have specifically asked to be named below, Data is supplied using legitimate interests and all client will use your information in line with our privacy policy for marketing purposes. This may mean that you receive advertising from them in relation to products or services which we believe are of interest to you based upon the information which you have provided us. To understand more about the products or services they offer please click through to their websites using the links below:

E. Credit Reference and Other Agencies

We will also share your details with credit reference and identity verification organisations which help other organisations verify your identity and prevent others from misusing your details. We share data using the legal basis of legitimate interests. These organisations will have a relationship withyou or need to use your information where they have a lawful reason, which will include these organisations’ own legitimate interest. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, byt not limited to , anti-money laundering regulation, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification. You have the right to object to this processing at any time by contacting us as compliance@lifestyle-choices.com.`