Pacifica Group Limited is committed to protecting the privacy of your personal information.
Your privacy is important to us and we go to great lengths to protect it. This Privacy Notice tells you about the personal data we hold about you and explains how we collect, use and share your details. It also tells you about your rights under data protection laws. We will only use your person information in accordance with this privacy policy
Pacifica Group is a collective name for the following companies, Pacifica Warranty, UK Warranty Limited and Pacifica Appliance Services Limited, our registered office address is Pacifica House, Rainton Business Park, Houghton Le Spring, England, DH4 5RA.
By downloading or using the Pluzs application (the "App"), using our services, entering a competition or prize draw, visiting or registering via our website or otherwise engaging with us, you're agreeing to be bound by this Policy. You should read this privacy policy carefully so that you understand how we will handle your personal information.
This is information relating to you as an individual, that’s linked to your name or any other way you can be identified, such as your insurance policy number, or your email address.
We may collect certain special category data about your physical health and/or medical condition if you require special assistance when an engineer attends your property.
Before and after we supply services or products to you, as well as collecting information from you directly, we also use external sources to find out more details about you and check the information collected. We also use this information for the purpose of conducting checks to prevent fraud, money laundering and sanction checks. When using your personal information in these ways, we have considered your rights and made sure our business need doesn’t cause you any harm.
The categories of personal information we may collect
Contact Data:
Your name and title, address, telephone number(s), personal e-mail address and any other contact details you may provide. If you are a landlord this could include your work contact details;
Identification Data:
Your first name, last name and title, your login credentials, your internet protocol (IP) address and information regarding which website pages you accessed and when;
Video and Image Data
You will be invited to upload videos and images of your appliances for warranty verification and appliance repair purposes. If you upload a video or photograph that captures your voice or image, the content will include your personal data;
Attendance Data
If an engineer attends your property to service or repair an appliance, the engineer will keep a service log with visit details;
Marketing and Communications Data
We may collect information about your marketing preferences if we are entitled to send you marketing materials, your communication preferences and your preferences in respect of third-party marketing;
This includes whether you’ve given your consent to receive marketing information.
Financial Data
Includes bank account and payment card details; and
Transaction Data
Includes details about products and services you have purchased from us. If you choose to use our receipt 'wallet' feature, any personal details contained in your appliance receipts will also be held.
Website and app use, including cookies and use of our web chat service
During your use of our website and mobile app, we automatically collect personal data about you that distinguishes you from other users by using Cookies. We may receive information that relates to your device, device settings, browser or other identifying information, in addition to information about your use of the service. We may also receive information about you if you visit other websites employing our cookies. Please see our Cookie Policy on our website for more details
Other information
This will be captured during recordings of any telephone calls, other contact with us or if you make a complaint. This may include special categories of information you provided when talking with us. We may capture this information (e.g., your contact details and recordings of the phone call) even if you are not a Pacifica customer. (e.g., if you are calling on behalf of a policyholder).
Please note that we may use In-bound and out-bound phone call recordings for uses as allowed for by UK law, including but not limited to FCA compliance rules, quality training and counter-fraud
Other Pacifica Group Companies
We may also use information that you provided to other Pacifica Group Companies or share it with them
We only collect and share your personal information when there is good reason to do so, and in line with all relevant data protection regulations. The following table is a list of where we obtain person information about you from, as well as who we share it with. Have also outlined the lawful basis (processing condition) which we rely on to use your personal information. All data needs one of the "General" processing conditions. However, where we are processing special category data, we also need one of the legal bases set out in the special category processing conditions. The key to the lawful bases is set out below the table.
Why we use your personal information including type of data and any Special Category data we record
Type of data
Data protection laws require you to have a processing condition (such as consent, or processing required by law) for processing all data. However, if the data is special category data (such as data relating to health data) we need an additional processing condition which reflects the increased privacy requirement of such data. In this column we list both the general processing condition and the special category processing condition which we rely on.
Lawful basis for processing (please see below for more information on legal bases)
App user/customer correspondence and engagement including social media, complaints and feedback;
Contact Data, Identification Data
General processing:
Legal obligation - the use of your personal information is necessary so that we are able to comply with regulations in responding to complaints.
Legitimate interest – it is a legitimate interest of ours to keep various information about you which will allow us to respond to your correspondence and improve our service for you and others.
Correspondence in regards to purchased warranties and guarantees, warranty expiry and renewal notifications;
Contract: the use of your personal information is necessary for the management and administration of your contract with us.
Legitimate interest – it is a legitimate interest of ours to keep various information about you which will allow us to notify you about your purchases and improve our service for you and others.
Booking an engineer to attend to your appliances;
Contact Data, Identification Data, Special Category Data
Explicit Consent: where you share special category data about your health, we will ask for your explicit consent to share this with an engineer before they attend your property so that they are in the best position to offer the right assistance to you.
Managing our contractual relationship with you;
Contact Data, Identification Data, Financial Data
Legitimate interests: it is a legitimate interest of ours to keep various information about you which is in addition to that which we need to fulfil our contractual obligations to you.
Marketing purposes; and
Contact Data, Identification Data, Marketing Purposes Data
Consent - If you have ticked the opt in box, we will send you electronic marketing information to your email address and via post, and via telephone, SMS and automated call based on the marketing preferences you've given to us. We will also send you push notifications. This would include information about how Pluzs is doing and activity on the App, reminders about upcoming services, renewals or maintenance, information about changes in our services or new services that we feel would be beneficial to you.
Legitimate interest – it is a legitimate interest of ours to keep various information about you which will allow us to notify you about similar products or services that we offer to those that you have already purchased or entered into negotiations about. Where we have already obtained or have sought consent, we will not rely on a legitimate interest.
Measure the effectiveness of the website and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
General Processing
Legitimate interests: it is our legitimate interest to ensure the effective running of our business (including our website), provision of administration and IT services, network security and in the context of a business reorganisation or group restructuring exercise.
We may share your personal data with the parties set out in the below table
Namely other companies in the Pacifica group acting as processors.
Pacifica Group Limited own all Pluzs software and intellectual property.
Pacifica Appliance Services Limited provide support and assistance, including sub-contracting engineers for the service and repair of appliances covered by a membership.
Service providers who provide us with services such as (without limitation) assisting us with postal printing and/or delivery, customer and technology support, payment services, [hosting services, fraud prevention and marketing, data enhancement,] advertising and market research services.
For example, we use:
Other service providers we may instruct include:
We process your personal information for different purposes. We must have legal permissions; this is called a lawful basis in order to process a person’s data and be able to demonstrate the processing of data is “necessary” in order to provide our products and services. We use the following process conditions:
Consent: your consent to one or more specific purposes. We will set out the basis for consent in a consent notice or in some other form of notice where it is clear we are asking for your consent. Where we do not get your consent, we will not use your data for that purpose;
Contract: it is necessary to process your data for the performance of a contract to which you are party or to meet our obligations under the contract;
Legitimate interests: we’ve identified this type of processing is a legitimate interest of ours or a third party to give you the best and most secure service and to provide you with the best service/product; we consider that use of your personal information is necessary to achieve that legitimate interest; and we’ve balanced all that against your interests, rights and freedoms. We set out more detail on our legitimate interest processing below at section
We sometimes process personal information on the basis that it is in our legitimate interests to do so. The occasions where we will rely on legitimate interests as our processing condition are set out above. The legitimate interests are as follows:
To maintain up to date information about you - we sometimes gather data about you which is useful for building a complete view of your use of the App and our website. Although some of this data is not strictly required by law, it is nevertheless useful to us and we consider it in our legitimate interest of running a successful, profitable business.
Network and information security – we will monitor our network and your use of it. It is a legitimate interest of ours to make sure that your use of our network and systems does not compromise our information security.
To procure insurance policies and to respond to and defend legal claims – it is in our legitimate interests to use your personal information where necessary in the purchase of insurance policies and to respond to and defend legal claims.
We will keep the personal information we store about you accurate and up to date. We will take every reasonable step to erase or rectify inaccurate data without delay. Please tell us if your personal details change or if you become aware of any inaccuracies in the personal information, we hold about you. We will contact you annually to check your details are still up-to-date. We will also contact you if we become aware of any event which is likely to result in a change to your personal information.
We keep personal information for as long as is reasonably required to allow us to manage complaints, claims, prevent fraud or financial crime, to meet our legal, regulatory obligations (e.g., as laid down by the Financial Conduct Authority, money laundering regulations and the HMRC, tax or account obligations. We will not keep your personal information for longer than is necessary for the purpose(s) for which we process it. This means that information will be destroyed or erased from our systems when it is no longer required. For guidance on how long certain information is likely to be kept before being destroyed, contact the Data Protection Officer on 01913870774 or by email at SubjectAccess.Request@pacifica.co.uk. For further information on the retention of your personal information, please contact the Data Protection Officer.
Under data protection law, you have different rights relating to the personal information we hold about you. You can exercise these tights by contacting us on SubjectAccess.Request@Pacifica.co.uk.
Below is a summary of your data protection Rights
You have a right to access a copy of your own personal information. We try to respond to all requests within one (1) calendar month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated on the progress of your request. We will request information from you in order to help us confirm your identity and ensure you have a right to access the personal information you have requested to see. This is a security measure to ensure that we do not disclose personal information to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request.
You will normally not have to pay a fee to access your personal information. However, we may charge a reasonable fee if your request is clearly unfounded or excessive (particularly where requests are repetitive). Alternatively, if your request is clearly unfounded or excessive, we may refuse to comply with your request.
This right enables you to have your data erased (the so-called "right to be forgotten"). The right relates only to personal information we hold at the time you make the request. There are also some important restrictions on this right.
In certain circumstances, be provided with the personal information that you have supplied to us, in a portable format that can be transmitted to another controller without hindrance.
We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you,
You have control over the extent to which we market to you and have the right to request we stop sending you marketing messages at any time. You can do this either by clicking on the ‘unsubscribe’ link or button in any email we send you or by contacting us. Even if you exercise this right because you do not want to receive marketing messages, we may still send you service-related communications where necessary.
In addition to the right to object to marketing, in certain circumstance you’ll have the right to object to use processing your personal information. This will be when we’re relying on there being a legitimate interest to process your personal information. In some circumstances, we will not be able to stop processing your information, but we’ll let you know if this is the case.
Require us to rectify any personal information which we hold about you which is inaccurate. Rectification enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you believe there are any inaccuracies, mistakes or gaps in the information we hold about you, you can contact us and ask us to update or amend it.
8Have the processing of your personal information restricted, in certain circumstances.
This enables you to ask us to suspend the processing of your personal information in the following scenarios:
The right to withdraw consent If we are processing any of your personal information based on you having given us consent to do so, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing we may have undertaken based on your consent before it is withdrawn.
If you wish to exercise any of the rights set out above, you must make the request in writing to the Data Protection Officer, email address SubjectAccess.Request@pacifica.co.uk.
If you provided your consent to any of the processing of your personal information, you have the right to withdraw your consent to that processing at any time, where relevant. Please contact the Data Protection Officer if you wish to do so.
You have a right to complain to the Information Commission Office if you believe that any use of your personal information by us is in breach of applicable data protection laws and/or regulations. More information can be found on the Information Commission Office website. This will not affect any other legal rights or remedies that you have. If you have any issues with our processing of your personal information and would like to make a complaint, you may contact the Information Commissioner's Office on 0303 123 1113 or at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Object to certain types of processing, including legitimate interests based processing and automated processing (which includes profiling) where we are processing your personal data on the basis of legitimate interests and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your interests, fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your interests, rights and freedoms or that the processing is required for the establishment, exercise or defence of legal claims.
There may be some circumstances where we cannot comply with your request. E.g., we wouldn’t be able to agree to your request if it meant we couldn’t comply with our own legal or regulatory requirements. In these instances, we’ll let you know why we cannot agree to your request.
We will not transfer your personal information outside the UK unless such transfer is compliant with the UK GDPR. This means that we cannot transfer any of your personal information outside the UK unless: the UK government has decided that another country or international organisation ensures an adequate level of protection for your personal information or the data is being transferred to a company in the US which has signed up to the UK-US data bridge; or the transfer of your personal information is subject to appropriate safeguards, which may include:
one of the derogations in the UK GDPR applies (including if you explicitly consent to the proposed transfer).
We currently transfer personal information outside the UK:
United States of America.
To effectively run our business, it is important that Pacifica can market its products or services. In doing so, we must follow various data protection regulations. These regulations mean that you always have the right to ask us to stop marketing to you, something which is called ‘opting out’. If we want to contact you electronically, we must have your consent before hand. We use the email address you gave us and remember how you prefer us to contact you.
If you have asked for (or started to request) a quotation or a price from us, either verbally or online, this expression of interest gives us permission to contact you to discuss out products – or to offer similar products and services to you, provided you haven’t opted out. This is called a soft opt in. You’re free to object to receive these messages or any other marketing material and can opted out at any time. You can do this either verbally when talking to one of our agents, email or post.
Service messages – There are occasions when we will contact you for non-marketing purposes. Because these service message do not contain any marketing, they fall outside of your marketing preferences (That means that even if you have opted-out of marketing, you will still receive them).
These messages fall into two categories:
We are required by the regulator to send the regulatory messages. Informational messages are sent using our Legitimate Interest and so you do have the right to request that we don’t (this is called the ‘Right to Object’). To request that right please contact the data protection office at SubjectAccess.Request.co.uk.
We will not keep your personal information for longer than is necessary for the purpose(s) for which we process it. This means that information will be destroyed or erased from our systems when it is no longer required. For guidance on how long certain information is likely to be kept before being destroyed, contact the Data Protection Officer on 01913870774 or by email at SubjectAccess.Request@pacifica.co.uk. For further information on the retention of your personal information, please contact the Data Protection Officer.
Keeping your data secure is important to us. We use reasonable and up to date security methods to keep your personal information secure and to prevent unauthorised or unlawful access to your personal information, and against the accidental loss of, or damage to, personal information.
Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal information.
We have in place procedures and technologies to maintain the security of all personal information from the point of collection to the point of destruction. These include adhering to various security standards, including physical and technological protection, data encryption, patching and software update management, management of access rights, vulnerability scanning and penetration testing, network configuration and monitoring. We will ensure your personal information is only accessible by those who need to see your information for their specific role. We will only transfer personal information to a third party if that third party agrees to comply with those procedures and policies, or if they put in place adequate measures themselves.
Our employees who need to access your data will view it in order that we can manage your engagement with us and comply with our legal and statutory duties. All of our employees have been trained in data protection and understand the need to keep your information confidential.
In addition to our employees, we also use third-party providers who may process personal information on our behalf to fulfil our promise to you. These providers are carefully selected professional contractors (such as your appliance engineer) who help us provide you with our services and will only collect, use and disclose your information to the extent necessary to allow them to perform these services. We have legally binding contractual agreements in place with any providers we may use to ensure that your data is secure at all times and cannot be accessed for any other purpose.
Apart from our employees and third-party providers, we will not disclose your personal information to a third party without your consent unless we are satisfied that they are legally entitled to the data. Where we do disclose your personal information to a third party, we will put in place arrangements to make sure your information is well protected and processed strictly in accordance with data protection laws.
We may disclose your personal information to third parties:
If your personal information is provided to any third parties, you are entitled to request details of the recipients of your personal information or the categories of recipients of your personal information.
If you have any issues with our processing of your personal information and would like to make a complaint, you may contact the Information Commissioner's Office on 0303 123 1113 or at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
If you want to exercise any of your rights (Your rights), or if you have any question about how we collect, store or use your personal information, our Data Protection Office can be as Follows
Post: Pacifica House, Rainton Business Park, Houghton Le Spring, England, DH4 5RA.
Email: SubjectAccess.Request@Pacifica.co.uk
Telephone: 01913870774