Privacy Policy

NewDay Technology Limited, trading as Imega (“we”, “us” or “our”), is incorporated in England and Wales with company number 08812602. Our registered office is 7 Handyside Street, London, N1C 4DA.

This policy sets out the basis on which your personal data will be processed by us when:

* You register as a member on our website
* You place an order on this site
* You fill out our contact form
* You browse our website. See “Cookie policy” below
* You fill out fields on your profile
* You use our services to show our retail finance software and process retail finance applications

For the purpose of data protection laws, Imegamedia Services Limited and True Innovation Limited are data controllers for our business customers.

TrueInnovation Limited is registered with the Information Commissioner’s Office - registration number ZA925646.

NewDay Technology Limited is registered with the Information Commissioner’s Office - registration number ZA779737.

We are committed to maintaining the privacy and protection of all personal data that we process in connection with our business.

This policy addresses how we process personal data as a controller. If you are a consumer making purchase with a retailer using our software, we act as a data processor on behalf of your retailer and your lender. In this case, the other business is responsible for the way in which your personal data is processed and their privacy policy will prevail.

If you have any questions regarding our privacy policy, please contact us (our contact details are set out in section 12).

1. Categories of information we collect from you

1.1 We will collect and process the following personal data.

1.2 Business customers:

• Name and role title
• Email address
• Telephone number

1.3 Consumers:

• Name
• Address
• Telephone number
• Email address
• Order details
• Finance account details
• IP address

1.4 We do not process any special categories of personal data, meaning personal data revealing:

1.4.1 racial or ethnic origin;

1.4.2 political opinions; religious or philosophical beliefs or trade union membership;

1.4.3 genetic or biometric data that uniquely identifies you; or

1.4.4 data concerning your health, sex life or sexual orientation.

1.5 We do not collect data relating to criminal convictions or offences or related security measures.

2. Our lawful basis for processing data as a controller

If you are a business customer interested in purchasing our services, we will process your personal data in order to take steps, at your request, to enter into a contract with you. Thereafter, we will process personal data to meet our legitimate interests - further details of these interests is shown below.

If you are a consumer applying for finance via a retailer who uses our technology services, we act as a data processor on behalf of the retailer and the lender, each of whom will have their own lawful basis for processing your personal data. 

Where we act as a data processor, we will have signed up to a Data Processing Agreement, setting out the specific uses and processing limitations agreed with the data controller. 

We set out below a brief summary of the type of data we process, why it is processed and the lawful basis for processing.

3. Third parties who we share personal data with

3.1 Business Customers:

We may share your limited personal information with other companies in the NewDay Group on the basis that we have a legitimate interest, where they may have products or services that may be beneficial to you.

3.2 Consumers:

As the data controllers for your personal data, your retailer and lender will be responsible for telling you how they will use your personal data and who they share it with.

4. Automated decision making

4.1 The nature of the service we provide to retailers and lenders does not require that we use your personal data to make automated decisions. If you are a consumer, any decisions made will be made by the lender in respect of your finance application.

5. Storing your personal data

5.1 The data that we collect from you will be stored in (and will not be transferred out of) the UK.

5.2 It we decide to use the services of any third party providers, which are based outside of the UK, we will ensure that the third party meets and maintains acceptable data protection and security measures and will enter into a contract that sets out additional clauses, protections and obligations for the parties to ensure any personal data processed is subject to robust protections in line with either the EU Standard Contractual Clauses or the UK International Data Transfer Agreement.

6. Period of storage

6.1 We store personal data only for as long as is necessary for us to provide our services and to meet any legal or contractual obligations to you as a business customer.

If you are a consumer applying for finance via a retailer who uses our services, we will only store your personal data for 7 days from the date you provide it. This is to ensure that the lender and/or retailer can access your data in case of a problem with your application. After 7 days, your personal data is securely deleted from our servers and will not be retrievable.

7. Security

7.1 We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. In particular we have taken steps to secure and safeguard the information we collect and transmit with the use of proven and effective security solutions.

7.2 The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7.3 All information you provide to us is stored on secure servers and all our systems are password protected to help ensure there is no unauthorised access to personal data. Where we have given you a password (or where you have subsequently changed that default password and chosen your own password), the password enables you to access certain parts of our website and you are responsible for keeping this password confidential. You must not share your password with anyone.

8. Your rights under data protection laws

Right to object

8.1 You have the right to object to us processing your personal data where we are processing personal data:

8.1.1 based on our legitimate interests (as set out in section 2 above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and

8.1.2 for direct marketing purposes. If you ask us to stop processing your personal data on this basis, we will stop. In each case please do so by making contact with us directly (please see section 12).

Right of access

8.2 You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing. You can exercise this right by making contact with us directly (please see section 12). 

If you are a consumer and wish to access your personal data, you should contact your lender or the retailer, as they are the controllers of your personal data.

Right to rectification

8.3 You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us. Right to restriction

Right to restrict processing

8.4 You have the right to restrict our processing of your personal data where:

8.4.1 the accuracy of the personal data is being contested by you;

8.4.2 the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased;

8.4.3 we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or

8.4.4 we are processing your data on the basis of our legitimate interest and you:

9. a) object to our processing on the basis of our legitimate interest under section 9.1.1 above; and

b)want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.

8.4.5 Where any exercise by you of your right to restriction determines that our processing of particular personal data is to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.

Right to data portability

8.5 You have the right to receive your personal data in structured, standard machine readable format and the right to transmit such personal data to another controller.

Right to erasure

8.6 You have the right to require we erase your personal data which we are processing where one of the following grounds applies:

8.6.1 the processing is no longer necessary in relation to the purposes for which your personal data was collected or otherwise processed;

8.6.2 our processing of your personal data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data;

8.6.3 you object to the processing of your personal data as set out in section

8.6.4 the personal data has been unlawfully processed; and

8.6.5 the erasure is required for compliance with a law to which we are subject.

Complaints

8.8 If you have cause to complain about our processing of your personal data, please contact us in the first instance, so that we can look to resolve the matter for you promptly. 

You have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), the supervisory authority for data protection issues in England and Wales. The ICO’s address is:       

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

8.9 Exercising your rights: You can exercise your rights by making contact with us directly (please see section 12). You will not generally be charged a fee for exercising any of your data protection rights and we must provide our response within one month of your request.

9. Cookies

9.1 Cookies are small text files which are set by us on your computer which allow us to provide certain functionality on our site, such as being able to log in, or remembering certain preferences.

10. Links on our website

Our website may, from time to time, contain links to and from the websites or platforms of our partner networks, affiliates and other third parties. Our service connects you to different websites or platforms. If you follow a link to any of these websites or platforms or use our service, please note that you have left our website and these websites and platforms have their own privacy policies and may collect or share personal data about you. We do not accept any responsibility or liability for these policies, websites or platforms. Please check these policies before submitting any personal data to these websites or platforms.

11. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this webpage and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

12. Contact

Questions, comments and requests regarding this privacy policy are welcomed.

You can contact us by writing to our Data Protection Officer using the email address dpofficer@newday.co.uk or via our postal address - NewDay Technology Limited, 7 Handyside Street, London, N1C 4DA .

This privacy policy was last updated on 30th September 2024.