My Work Pension

BACKGROUND:

Trafalgar House Pensions Administration Limited understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 15, below;

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“Our Site”

means this website, www2.myworkpension.co.uk;

“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);

“UK and EU Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and

“We/Us/Our”

means Trafalgar House Pensions Administration Limited, a limited company registered in England under 11101662, whose registered address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN and whose main trading address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN.

2. Information About Us

2.1

Our Site, www2.myworkpension.co.uk, is owned and operated by Trafalgar House Pensions Administration Limited, a limited company registered in England under 11101662, whose registered address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN.

2.2

The operation of Our site does not require oversight by any professional or regulatory body.

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). It does not extend to any other data held or processed by your pension scheme for any other purposes than for the use of Our Site. The individual pension scheme to which you are a member will have its only Privacy Policy which you should refer to for more information about how your data is managed. We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.11

The right to be informed about Our collection and use of personal data;

4.12

The right of access to the personal data We hold about you;

4.13

The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 16);

4.14

In certain circumstances, the right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you;

4.15

In certain circumstances, the right to restrict (i.e. prevent) the processing of your personal data;

4.16

The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.17

The right to object to Us using your personal data for particular purposes; and

4.18

Rights with respect to automated decision making and profiling.

4.2

If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 16 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3

For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Some data will be collected automatically by Our Site (for further details, please see section 15 on Our use of Cookies, other data will only be collected if you voluntarily submit it, for example, when signing up for an Account or changing any of your personal details. Depending upon your use of Our Site, We may collect some or all of the following data.

5.1

personal details such as your name, gender, age, date of birth, contact details (e.g. your address and postcode, email, telephone and mobile numbers), and identifiers such as your National Insurance number, pension or member reference number and employee number (where applicable);

5.2

employment details such as your earnings, length of service, employment and career history, recruitment and termination details, absence record, job title and job responsibilities;

5.3

other financial details such as about any other income, other pension arrangements, bank account details (e.g. to process pension payments) and tax code;

5.4

demographic information such as post code, preferences and interests;

5.5

IP address (automatically collected);

5.6

web browser type and version (automatically collected);

5.7

operating system (automatically collected); and

5.8

a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)

6. How Do We Use Your Data?

6.1

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.

6.2

Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with the trustees of the pension scheme for which you are a member, because you have consented to Our use of your personal data, or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.3

We use your data to provide the best possible services to you. This includes:

6.3.1

calculating and paying benefits to you due from your pension scheme;

6.3.2

providing and managing your Account;

6.3.3

providing and managing your access to Our Site;

6.3.4

personalising and tailoring your experience on Our Site;

6.3.5

supplying pension administration services to you;

6.3.6

personalising and tailoring Our services for you;

6.3.7

responding to communications from you;

6.3.8

complying with our legal obligations, any relevant industry or professional rules and regulations or any applicable voluntary codes

6.3.9

supplying you with email newsletters, alerts and invitations to events that you have subscribed to (you may unsubscribe or opt-out at any time by following the unsubscribe links provided or by emailing us at contactus@thpa.co.uk;

6.3.10

market research; and

6.3.11

analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

6.4

With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information and news on services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.5

Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 15. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

6.6

You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

7. How and Where Do We Store Your Data?

7.1

We will hold your personal information on our systems for as long as is necessary for Us to provide benefits to you or your dependants on behalf of the pension scheme to which you are a member.

7.2

Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).

7.3

Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

7.4

Steps We take to secure and protect your data include:

7.4.1

servers being protected with firewalls;

7.4.2

access to data being restricted to authorised personnel; and

7.4.3

data being published and exchanged with Our Site being encrypted.

8. Do We Share Your Data?

8.1

We may share your data with other companies in Our group. This includes Our holding company and its subsidiaries.

8.2

We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, search engine facilities, address tracing or identity verification service providers. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.3

In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

9. How The Law Protects You

Your privacy is protected by law. This sections explains how that works

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside of Trafalgar House Pensions Administration Ltd. The law says we must have one or more of these reasons:

To fulfil a contract with you, or

When it is our legal duty, or

When it is in our legitimate interest or

When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you.

10. What Happens If Our Business Changes Hands?

10.1

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

10.2

In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

11. How Can You Control Your Data?

11.1

When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

11.2

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Your Right to Withhold Information

12.1

You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you will be required to submit or allow for the collection of certain data.

12.2

You may restrict your internet browser’s use of Cookies. For more information, see section 15.9.

13. How Can You Access Your Data

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at contactus@thpa.co.uk, or using the contact details below in section 16.

14. What is a Cookie

Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs, such as remembering preferences, and generally improving your online experience.

There are different types of cookies. They all work in the same way but have minor differences.

15. What Cookies Do We Use and What For

15.1

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. For more details, please refer to section 5, above, and to section 15.5 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

15.2

All Cookies used by and on Our Site are used in accordance with current UK and EU Cookie Law.

15.3

Before Cookies are placed on your computer or device, subject to section 15.4, you will be shown a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

15.4

Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 15.5. Your consent will not be sought to place these Cookies. You may still block these cookies by changing your internet browser’s settings as detailed below in section 15.9, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

15.5

The following first party Cookies may be placed on your computer or device.

Name of Cookie	Purpose	Strictly Necessary	Policy
Contact form	Contacting the User	No	By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Geolcation	Location-based interactions	No	This Application may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
Mailing list or newsletter	Contacting the User	No	By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Unique device identification	Further information about Personal Data	No	This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

15.6

Our Site uses analytics services provided by Google Inc. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

15.7

The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 15.9.

15.8

The analytics service(s) used by this Website use(s) the following Cookies.

Name of Cookie	First / Third Party	Provider	Purpose
Google Analytics	Third Party	Google Inc.	Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

15.9

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

15.10

You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

15.11

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

16. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at contactus@thpa.co.uk, by telephone on 0203 985 3079, or by post at Trafalgar House Pensions Administration Limited, Trafalgar House, PO Box 131, Blyth NE24 9FB. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 13, above).

17. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

BACKGROUND:

Trafalgar House Pensions Administration Limited understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 15, below;

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“Our Site”

means this website, www2.myworkpension.co.uk;

“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);

“UK and EU Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and

“We/Us/Our”

means Trafalgar House Pensions Administration Limited, a limited company registered in England under 11101662, whose registered address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN and whose main trading address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN.

2. Information About Us

2.1

Our Site, www2.myworkpension.co.uk, is owned and operated by Trafalgar House Pensions Administration Limited, a limited company registered in England under 11101662, whose registered address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN.

2.2

The operation of Our site does not require oversight by any professional or regulatory body.

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). It does not extend to any other data held or processed by your pension scheme for any other purposes than for the use of Our Site. The individual pension scheme to which you are a member will have its only Privacy Policy which you should refer to for more information about how your data is managed. We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.11

The right to be informed about Our collection and use of personal data;

4.12

The right of access to the personal data We hold about you;

4.13

The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 16);

4.14

In certain circumstances, the right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you;

4.15

In certain circumstances, the right to restrict (i.e. prevent) the processing of your personal data;

4.16

The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.17

The right to object to Us using your personal data for particular purposes; and

4.18

Rights with respect to automated decision making and profiling.

4.2

If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 16 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3

For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Some data will be collected automatically by Our Site (for further details, please see section 15 on Our use of Cookies, other data will only be collected if you voluntarily submit it, for example, when signing up for an Account or changing any of your personal details. Depending upon your use of Our Site, We may collect some or all of the following data.

5.1

personal details such as your name, gender, age, date of birth, contact details (e.g. your address and postcode, email, telephone and mobile numbers), and identifiers such as your National Insurance number, pension or member reference number and employee number (where applicable);

5.2

employment details such as your earnings, length of service, employment and career history, recruitment and termination details, absence record, job title and job responsibilities;

5.3

other financial details such as about any other income, other pension arrangements, bank account details (e.g. to process pension payments) and tax code;

5.4

demographic information such as post code, preferences and interests;

5.5

IP address (automatically collected);

5.6

web browser type and version (automatically collected);

5.7

operating system (automatically collected); and

5.8

a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)

6. How Do We Use Your Data?

6.1

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.

6.2

Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with the trustees of the pension scheme for which you are a member, because you have consented to Our use of your personal data, or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.3

We use your data to provide the best possible services to you. This includes:

6.3.1

calculating and paying benefits to you due from your pension scheme;

6.3.2

providing and managing your Account;

6.3.3

providing and managing your access to Our Site;

6.3.4

personalising and tailoring your experience on Our Site;

6.3.5

supplying pension administration services to you;

6.3.6

personalising and tailoring Our services for you;

6.3.7

responding to communications from you;

6.3.8

complying with our legal obligations, any relevant industry or professional rules and regulations or any applicable voluntary codes

6.3.9

supplying you with email newsletters, alerts and invitations to events that you have subscribed to (you may unsubscribe or opt-out at any time by following the unsubscribe links provided or by emailing us at contactus@thpa.co.uk;

6.3.10

market research; and

6.3.11

analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

6.4

With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information and news on services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.5

Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 15. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

6.6

You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

7. How and Where Do We Store Your Data?

7.1

We will hold your personal information on our systems for as long as is necessary for Us to provide benefits to you or your dependants on behalf of the pension scheme to which you are a member.

7.2

Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).

7.3

Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

7.4

Steps We take to secure and protect your data include:

7.4.1

servers being protected with firewalls;

7.4.2

access to data being restricted to authorised personnel; and

7.4.3

data being published and exchanged with Our Site being encrypted.

8. Do We Share Your Data?

8.1

We may share your data with other companies in Our group. This includes Our holding company and its subsidiaries.

8.2

We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, search engine facilities, address tracing or identity verification service providers. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.3

In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

9. How The Law Protects You

Your privacy is protected by law. This sections explains how that works

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside of Trafalgar House Pensions Administration Ltd. The law says we must have one or more of these reasons:

To fulfil a contract with you, or

When it is our legal duty, or

When it is in our legitimate interest or

When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you.

10. What Happens If Our Business Changes Hands?

10.1

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

10.2

In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

11. How Can You Control Your Data?

11.1

When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

11.2

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Your Right to Withhold Information

12.1

You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you will be required to submit or allow for the collection of certain data.

12.2

You may restrict your internet browser’s use of Cookies. For more information, see section 15.9.

13. How Can You Access Your Data

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at contactus@thpa.co.uk, or using the contact details below in section 16.

14. What is a Cookie

Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs, such as remembering preferences, and generally improving your online experience.

There are different types of cookies. They all work in the same way but have minor differences.

15. What Cookies Do We Use and What For

15.1

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. For more details, please refer to section 5, above, and to section 15.5 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

15.2

All Cookies used by and on Our Site are used in accordance with current UK and EU Cookie Law.

15.3

Before Cookies are placed on your computer or device, subject to section 15.4, you will be shown a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

15.4

Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 15.5. Your consent will not be sought to place these Cookies. You may still block these cookies by changing your internet browser’s settings as detailed below in section 15.9, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

15.5

The following first party Cookies may be placed on your computer or device.

Name of Cookie	Purpose	Strictly Necessary	Policy
Contact form	Contacting the User	No	By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Geolcation	Location-based interactions	No	This Application may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
Mailing list or newsletter	Contacting the User	No	By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Unique device identification	Further information about Personal Data	No	This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

15.6

Our Site uses analytics services provided by Google Inc. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

15.7

The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 15.9.

15.8

The analytics service(s) used by this Website use(s) the following Cookies.

Name of Cookie	First / Third Party	Provider	Purpose
Google Analytics	Third Party	Google Inc.	Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

15.9

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

15.10

You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

15.11

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

16. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at contactus@thpa.co.uk, by telephone on 0203 985 3079, or by post at Trafalgar House Pensions Administration Limited, Trafalgar House, PO Box 131, Blyth NE24 9FB. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 13, above).

17. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

BACKGROUND:

These Terms and Conditions, together with any and all other documents referred to herein, set out the terms of use under which you may use this website, www2.myworkpension.co.uk (“Our Site”). Please read these Terms and Conditions carefully and ensure that you understand them. Your agreement to comply with and be bound by these Terms and Conditions is deemed to occur upon your first use of Our Site. If you do not agree to comply with and be bound by these Terms and Conditions, you must stop using Our Site immediately.

1. Definitions and Interpretation

1.1 In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:.

“Account”

means an account required for a User to access certain areas of Our Site, as detailed in Clause 4;

“Content”

means any and all text, images, audio, video, scripts, code, software, databases and any other form of information capable of being stored on a computer that appears on, or forms part of, Our Site;

“Our Site”

means this website, www2.myworkpension.co.uk and a reference to “Our Site” includes reference to any and all Content included therein (including User Content, unless expressly stated otherwise);

“User”

means a user of Our Site;

“User Content”

means names, residential addresses, bank account details, marital status, telephone numbers, email address, information about your dependents, contact preferences, next of kin, pension and investment options submitted by Users to Our Site; and

“We/Us/Our”

means Trafalgar House Pensions Administration Limited, a company registered in England under 11101662, whose registered address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN.

2. Information About Us

2.1 Our Site, www2.myworkpension.co.uk, is owned and operated by Trafalgar House Pensions Administration Limited, a limited company registered in England under 11101662, whose registered address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN.

2.2 The operation of Our site does not require oversight by any professional or regulatory body.

3. Access to Our Site

3.1 Access to Our Site is free of charge.

3.2 It is your responsibility to make any and all arrangements necessary in order to access Our Site.

3.3 Access to Our Site is provided “as is” and on an “as available” basis. We may alter, suspend or discontinue Our Site (or any part of it) at any time and without notice. We will not be liable to you in any way if Our Site (or any part of it) is unavailable at any time and for any period.<

4. Accounts

4.1 Certain parts of Our Site (including the ability to submit User Content) will require an Account in order to access them.

4.2 When creating an Account, the information you provide must be accurate and complete. If any of your information changes at a later date, it is your responsibility to ensure that your Account is kept up-to-date.

4.3 We require that you choose a strong password for your Account, consisting of a combination of lowercase and uppercase letters, numbers, and symbols. It is your responsibility to keep your password safe. You must not share your Account with anyone else. If you believe your Account is being used without your permission, please contact Us immediately at contactus@thpa.co.uk. We will not be liable for any unauthorised use of your Account.

4.4 You must not use anyone else’s Account without the express permission of the User to whom the Account belongs.

4.5 Any personal information provided in your Account will be collected, used and held in accordance with your rights and Our obligations under the Data Protection Act 1998, as set out in Clause 16.

4.6 If you wish to close your Account, you may do so at any time. Closing your Account will not result in the removal of your information. Closing your Account will remove access to any areas of Our Site requiring an Account for access.

5. Intellectual Property Rights and Our Site

5.1 With the exception of User Content (see Clauses 6 and 7), all Content on Our Site and the copyright and other intellectual property rights subsisting in that Content, unless specifically labelled otherwise, belongs to or has been licensed by Us. All Content (including User Content) is protected by applicable United Kingdom and international intellectual property laws and treaties.

5.2 Subject to the licence granted to Us under sub-Clause 6.5, Users retain the ownership of copyright and other intellectual property rights subsisting in User Content submitted by them (unless any part of such User Content is owned by a third party who has given their express permission for their material to be used in the User Content).

5.3 For personal use only, you may:

5.3.1 Access, view and use Our Site in a web browser (including any web browsing capability built into other types of software or app);

5.3.2 Download any Content where we have provided a link enabling you to do so;

5.3.3 Download Our Site (or any part of it) for caching;

5.3.4 Print pages from Our Site;

5.3.5 Download, copy, clip, print, or otherwise save extracts from pages on Our Site;

5.3.6 Save pages from Our Site for later and/or offline viewing;

5.3.7 View and use User Content in accordance with the permissions displayed with that User Content and set out in Clause 7;

5.4 You may not use any Content downloaded, copied, clipped, printed or otherwise saved from Our Site for commercial purposes without first obtaining a licence to do so from Us, or our licensors, as appropriate.

5.5 You may not systematically copy Content from Our Site with a view to creating or compiling any form of comprehensive collection, compilation, directory, or database unless given Our express permission to do so.

5.6 Subject to sub-Clauses 5.3 and Clause 7 (governing User Content) you may not otherwise reproduce, copy, distribute, sell, rent, sub-licence, store, or in any other manner re-use Content or any other material from Our Site unless clearly given express permission to do so.

5.7 Our status as the owner and author of the Content on Our Site (or that of identified licensors or Users, as appropriate) must always be acknowledged.

6. User Content

6.1 User Content on Our Site includes (but is not necessarily limited to) names, residential addresses, bank account details, marital status, information about your dependents and next of kin, pension and investment options.

6.2 An Account is required if you wish to submit User Content. Please refer to Clause 4 for more information.

6.3 You agree that you will be solely responsible for your User Content. Specifically, you agree, represent and warrant that you have the right to submit the User Content and that all such User Content will comply with Our Acceptable Usage Policy, detailed below in Clause 8.

6.4 You agree that you will be liable to Us and will, to the fullest extent permissible by law, indemnify Us for any breach of the warranties given by you under sub-Clause 6.3. You will be responsible for any loss or damage suffered by Us as a result of such breach.

7. Acceptable Usage Policy

7.1 You may only use Our Site in a manner that is lawful and that complies with the provisions of this Clause 7. Specifically:

7.1.1 you must ensure that you comply fully with any and all applicable local, national, and international laws and/or regulations;

7.1.2 you must not use Our Site in any way, or for any purpose, that is unlawful or fraudulent;

7.1.3 you must not use Our Site to knowingly send, upload, or in any other way transmit data that contains any form of virus or other malware, or any other code designed to adversely affect computer hardware, software, or data of any kind; and

7.1.4 you must not use Our Site in any way, or for any purpose, that is intended to harm any person or persons in any way.

7.2 When submitting User Content (or communicating in any other way using Our Site), you must not submit, communicate or otherwise do anything that:

7.2.1 is obscene, deliberately offensive, hateful, or otherwise inflammatory;

7.2.2 promotes violence;

7.2.3 promotes or assists in any form of unlawful activity;

7.2.4 discriminates against, or is in any way defamatory of, any person, group or class of persons, race, sex, religion, nationality, disability, sexual orientation, or age;

7.2.5 is intended or otherwise likely to threaten, harass, annoy, alarm, inconvenience, upset, or embarrass another person;

7.2.6 is calculated or otherwise likely to deceive;

7.2.7 is intended or otherwise likely to infringe (or threaten to infringe) another person’s right to privacy;

7.2.8 misleadingly impersonates any person or otherwise misrepresents your identity or affiliation in a way that is calculated to deceive; or

7.2.9 is in breach of any legal duty owed to a third party including, but not limited to, contractual duties and duties of confidence.

7.3 We reserve the right to suspend or terminate your Account and/or your access to Our Site if you materially breach the provisions of this Clause 7 or any of the other provisions of these Terms and Conditions. Specifically, We may take one or more of the following actions:

7.3.1 suspend, whether temporarily or permanently, your Account and/or your right to access Our Site;

7.3.2 issue you with a written warning;

7.3.3 take legal proceedings against you for reimbursement of any and all relevant costs on an indemnity basis resulting from your breach;

7.3.4 take further legal action against you as appropriate;

7.3.5 disclose such information to law enforcement authorities as required or as We deem reasonably necessary; and/or

7.3.6 any other actions which We deem reasonably appropriate (and lawful).

7.4 We hereby exclude any and all liability arising out of any actions (including, but not limited to those set out above) that We may take in response to breaches of these Terms and Conditions.

8. Links to Our Site

8.1 You may link to Our Site provided that:

8.1.1 you do so in a fair and legal manner;

8.1.2 you do not do so in a manner that suggests any form of association, endorsement or approval on Our part where none exists;

8.1.3 you do not use any logos or trade marks displayed on Our Site without Our express written permission; and

8.1.4 you do not do so in a way that is calculated to damage Our reputation or to take unfair advantage of it.

8.2 You may not link to any page other than the homepage of Our Site, www2.myworkpension.co.uk. Deep-linking to other pages requires Our express written permission.

8.3 Framing or embedding of Our Site on other websites is not permitted without Our express written permission.

8.4 You may not link to Our Site from any other site the content of which contains material that:

8.4.1 is sexually explicit;

8.4.2 is obscene, deliberately offensive, hateful or otherwise inflammatory;

8.4.3 promotes violence;

8.4.4 promotes or assists in any form of unlawful activity;

8.4.5 discriminates against, or is in any way defamatory of, any person, group or class of persons, race, sex, religion, nationality, disability, sexual orientation, or age;

8.4.6 is intended or is otherwise likely to threaten, harass, annoy, alarm, inconvenience, upset, or embarrass another person;

8.4.7 is calculated or is otherwise likely to deceive;

8.4.8 is intended or is otherwise likely to infringe (or to threaten to infringe) another person’s privacy;

8.4.9 misleadingly impersonates any person or otherwise misrepresents the identity or affiliation of a particular person in a way that is calculated to deceive (obvious parodies are not included in this definition provided that they do not fall within any of the other provisions of this sub-Clause 9.4);

8.4.10 implies any form of affiliation with Us where none exists;

8.4.11 infringes, or assists in the infringement of, the intellectual property rights (including, but not limited to, copyright, patents, trade marks and database rights) of any other party; or

8.4.12 is made in breach of any legal duty owed to a third party including, but not limited to, contractual duties and duties of confidence.

9. Links to Other Sites

Links to other sites may be included on Our Site. Unless expressly stated, these sites are not under Our control. We neither assume nor accept responsibility or liability for the content of third party sites. The inclusion of a link to another site on Our Site is for information only and does not imply any endorsement of the sites themselves or of those in control of them.

10. Disclaimers and Legal Rights

10.1 Nothing on Our Site constitutes advice on which you should rely. It is provided for general information purposes only. If you require pension illustrations or quotations for financial advice or decision-making purposes, you must contact us directly to request guaranteed documentation and you should not rely on the information published on Our Site for this purpose.

10.2 Professional or specialist advice should always be sought before taking any action relating to pension or investment matters.

10.3 Insofar as is permitted by law, We make no representation, warranty, or guarantee that Our Site will meet your requirements, that it will not infringe the rights of third parties, that it will be compatible with all software and hardware, or that it will be secure.

10.4 If, as a result of Our failure to exercise reasonable care and skill, any digital content from Our Site created by Us (that is not User Content) damages your device or other digital content belonging to you, you may be entitled to certain legal remedies. For more details concerning your rights and remedies as a consumer, please contact your local Citizens Advice Bureau or Trading Standards Office.

10.5 We make reasonable efforts to ensure that Our Content on Our Site is complete, accurate, and up-to-date. We do not, however, make any representations, warranties or guarantees (whether express or implied) that such Content is complete, accurate, or up-to-date.

11. Our Liability

11.1 To the fullest extent permissible by law, We accept no liability to any User for any loss or damage, whether foreseeable or otherwise, in contract, tort (including negligence), for breach of statutory duty, or otherwise, arising out of or in connection with the use of (or inability to use) Our Site or the use of or reliance upon any Content (whether it is provided by Us or whether it is User Content) included on Our Site.

11.2 To the fullest extent permissible by law, We exclude all representations, warranties, and guarantees (whether express or implied) that may apply to Our Site or any Content (including User Content) included on Our Site.

11.3 Our Site is intended for non-commercial use only. If you are a business user, We accept no liability for loss of profits, sales, business or revenue; loss of business opportunity, goodwill or reputation; loss of anticipated savings; business interruption; or for any indirect or consequential loss or damage.

11.4 We exercise all reasonable skill and care to ensure that Our Site is free from viruses and other malware. Subject to sub-Clause 12.3, We accept no liability for any loss or damage resulting from a virus or other malware, a distributed denial of service attack, or other harmful material or event that may adversely affect your hardware, software, data or other material that occurs as a result of your use of Our Site (including the downloading of any Content (including User Content) from it) or any other site referred to on Our Site.

11.5 We neither assume nor accept responsibility or liability arising out of any disruption or non-availability of Our Site resulting from external causes including, but not limited to, ISP equipment failure, host equipment failure, communications network failure, natural events, acts of war, or legal restrictions and censorship.

11.6 Nothing in these Terms and Conditions excludes or restricts Our liability for fraud or fraudulent misrepresentation, for death or personal injury resulting from negligence, or for any other forms of liability which cannot be excluded or restricted by law. For full details of consumers’ legal rights, including those relating to digital content, please contact your local Citizens’ Advice Bureau or Trading Standards Office.

12. Viruses, Malware and Security

12.1 We exercise all reasonable skill and care to ensure that Our Site is secure and free from viruses and other malware. We do not, however, guarantee that Our Site is secure or free from viruses or other malware and accept no liability in respect of the same.

12.2 You are responsible for protecting your hardware, software, data and other material from viruses, malware, and other internet security risks.

12.3 You must not deliberately introduce viruses or other malware, or any other material which is malicious or technologically harmful either to or via Our Site.

12.4 You must not attempt to gain unauthorised access to any part of Our Site, the server on which Our Site is stored, or any other server, computer, or database connected to Our Site.

12.5 You must not attack Our Site by means of a denial of service attack, a distributed denial of service attack, or by any other means.

12.6 By breaching the provisions of sub-Clauses 12.3 to 12.5 you may be committing a criminal offence under the Computer Misuse Act 1990. Any and all such breaches will be reported to the relevant law enforcement authorities and We will cooperate fully with those authorities by disclosing your identity to them. Your right to use Our Site will cease immediately in the event of such a breach.

13. Privacy and Cookies

Use of Our Site is also governed by our Cookie policy and Privacy Policy. These policies are incorporated into these Terms and Conditions by this reference.

14. Data Protection

14.1 All personal information that We may collect (including, but not limited to, your name and contact details) will be collected, used and held in accordance with the provisions of the Data Protection Act 1998 and your rights and Our obligations under that Act.

14.2 We may use your personal information to:

14.2.1 Provide and administer your Account;

14.2.2 Reply to any communications you send to Us;

14.2.3 Send you important notices, as detailed in Clause 15; or

14.2.4 Provide you with information about your pension.

15. Communications from Us

15.1 If you have an Account, We may from time to time send you important notices by email. Such notices may relate to matters including, but not limited to, service changes, changes to these Terms and Conditions, and changes to your Account.

15.2 We will never send you marketing emails of any kind.

15.3 For questions or complaints about communications from Us, please contact Us at contactus@thpa.co.uk.

16. Changes to these Terms and Conditions

16.1 We may alter these Terms and Conditions at any time. Any such changes will become binding on you upon your first use of Our Site after the changes have been implemented. You are therefore advised to check this page from time to time.

16.2 In the event of any conflict between the current version of these Terms and Conditions and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.

17. Contacting Us

To contact Us, please use our contact form.

18. Law and Jurisdiction

18.1 These Terms and Conditions, and the relationship between you and Us (whether contractual or otherwise) shall be governed by, and construed in accordance with, English law.

18.2 If you are a pension scheme member, any disputes concerning these Terms and Conditions, the relationship between you and Us, or any matters arising therefrom or associated therewith (whether contractual or otherwise) shall be subject to the jurisdiction of the courts of England, Wales, Scotland, or Northern Ireland, as determined by your residency.

18.3 If you are a business, any disputes concerning these Terms and Conditions, the relationship between you and Us, or any matters arising therefrom or associated therewith (whether contractual or otherwise) shall be subject to the exclusive jurisdiction of the courts of England and Wales.

Pension Scams

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One Ecolab Pension Plan

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 15, below;
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“Our Site”	means this website, www2.myworkpension.co.uk;
“personal data”	means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
“UK and EU Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our”	means Trafalgar House Pensions Administration Limited, a limited company registered in England under 11101662, whose registered address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN and whose main trading address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN.

2.1	Our Site, www2.myworkpension.co.uk, is owned and operated by Trafalgar House Pensions Administration Limited, a limited company registered in England under 11101662, whose registered address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN.
2.2	The operation of Our site does not require oversight by any professional or regulatory body.

4.1	As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
	4.11	The right to be informed about Our collection and use of personal data;
	4.12	The right of access to the personal data We hold about you;
	4.13	The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 16);
	4.14	In certain circumstances, the right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you;
	4.15	In certain circumstances, the right to restrict (i.e. prevent) the processing of your personal data;
	4.16	The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
	4.17	The right to object to Us using your personal data for particular purposes; and
	4.18	Rights with respect to automated decision making and profiling.
4.2	If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 16 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3	For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5.1	personal details such as your name, gender, age, date of birth, contact details (e.g. your address and postcode, email, telephone and mobile numbers), and identifiers such as your National Insurance number, pension or member reference number and employee number (where applicable);
5.2	employment details such as your earnings, length of service, employment and career history, recruitment and termination details, absence record, job title and job responsibilities;
5.3	other financial details such as about any other income, other pension arrangements, bank account details (e.g. to process pension payments) and tax code;
5.4	demographic information such as post code, preferences and interests;
5.5	IP address (automatically collected);
5.6	web browser type and version (automatically collected);
5.7	operating system (automatically collected); and
5.8	a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)

6.1	All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.
6.2	Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with the trustees of the pension scheme for which you are a member, because you have consented to Our use of your personal data, or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.3	We use your data to provide the best possible services to you. This includes:
	6.3.1	calculating and paying benefits to you due from your pension scheme;
	6.3.2	providing and managing your Account;
	6.3.3	providing and managing your access to Our Site;
	6.3.4	personalising and tailoring your experience on Our Site;
	6.3.5	supplying pension administration services to you;
	6.3.6	personalising and tailoring Our services for you;
	6.3.7	responding to communications from you;
	6.3.8	complying with our legal obligations, any relevant industry or professional rules and regulations or any applicable voluntary codes
	6.3.9	supplying you with email newsletters, alerts and invitations to events that you have subscribed to (you may unsubscribe or opt-out at any time by following the unsubscribe links provided or by emailing us at contactus@thpa.co.uk;
	6.3.10	market research; and
	6.3.11	analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.4	With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information and news on services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.5	Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 15. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.6	You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

7.1	We will hold your personal information on our systems for as long as is necessary for Us to provide benefits to you or your dependants on behalf of the pension scheme to which you are a member.
7.2	Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
7.3	Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4	Steps We take to secure and protect your data include:
	7.4.1	servers being protected with firewalls;
	7.4.2	access to data being restricted to authorised personnel; and
	7.4.3	data being published and exchanged with Our Site being encrypted.

8.1	We may share your data with other companies in Our group. This includes Our holding company and its subsidiaries.
8.2	We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, search engine facilities, address tracing or identity verification service providers. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3	In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

10.1	We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
10.2	In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

11.1	When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
11.2	You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12.1	You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you will be required to submit or allow for the collection of certain data.
12.2	You may restrict your internet browser’s use of Cookies. For more information, see section 15.9.

15.1	Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. For more details, please refer to section 5, above, and to section 15.5 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.
15.2	All Cookies used by and on Our Site are used in accordance with current UK and EU Cookie Law.
15.3	Before Cookies are placed on your computer or device, subject to section 15.4, you will be shown a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
15.4	Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 15.5. Your consent will not be sought to place these Cookies. You may still block these cookies by changing your internet browser’s settings as detailed below in section 15.9, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
15.5	The following first party Cookies may be placed on your computer or device.

15.6	Our Site uses analytics services provided by Google Inc. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
15.7	The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 15.9.
15.8	The analytics service(s) used by this Website use(s) the following Cookies.

15.9	You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
15.10	You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
15.11	It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

“Account”	means an account required for a User to access certain areas of Our Site, as detailed in Clause 4;
“Content”	means any and all text, images, audio, video, scripts, code, software, databases and any other form of information capable of being stored on a computer that appears on, or forms part of, Our Site;
“Our Site”	means this website, www2.myworkpension.co.uk and a reference to “Our Site” includes reference to any and all Content included therein (including User Content, unless expressly stated otherwise);
“User”	means a user of Our Site;
“User Content”	means names, residential addresses, bank account details, marital status, telephone numbers, email address, information about your dependents, contact preferences, next of kin, pension and investment options submitted by Users to Our Site; and
“We/Us/Our”	means Trafalgar House Pensions Administration Limited, a company registered in England under 11101662, whose registered address is Trafalgar House, Ascent 4, 2 Gladiator Way, Farnborough Aerospace Centre, Farnborough, Hampshire GU14 6XN.

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