1. Who Are We?
2. How we and our panel of mobile phone providers may contact you as part of your mobile application
3. How you contact us
4. How we keep you informed
5. Obtaining Personal Data / Information
6. Customer Communication
7. What personal information do we collect?
8. Who do we share your personal information with?
9. How do we use your personal information?
10. What cookies do we use?
11. How secure is our site and what steps do we take to keep you safe?
12. Rights of access to your personal information
13. How long will we retain your personal information for?
14. How to make a complaint

1. Who Are We?

Topcatalogues.co.uk  is a trading name of Pathfind Media Ltd. Pathfind Media Ltd is licenced by the Information Commissioners Office, (Registration Number ZA121279), Registered in the UK, number 09544182. Registered office: 2 Wellington Place, Leeds, LS1 4AP

Pathfind Media are aware of how important your privacy is, based on this we have implemented measures which will ensure any personal information that is obtained from you by visiting our website will be processed and maintained in line with accepted principles of good information handling and in accordance with the General Data Protection Regulation (GDPR). This Privacy policy contains details of the type of information that we collect via our website Topcatalogues.co.uk and may hold about you as our customer, also how we obtain and process any information we may have and importantly how we protect your privacy.

This privacy policy is only applicable to us and personal information which may be collected and obtained by us. Topcatalogues.co.uk  may choose to amend the content of this privacy policy on occasion. If this occurs, then we will update the policy and the revised policy will be posted on this website.

2. How we may contact you as part of your phone contract enquiry

We and our selection of mobile phone contract providers, will keep you informed with the progress of your enquiry. Unless you state otherwise you may be contacted via telephone, email, SMS and automated message. (see further section on 'How we keep you informed')

Lawful basis for collecting your personal data

We rely upon a different lawful basis to process your personal data according to the reason for which you have provided your data to us.

Our use of your personal data will always have a lawful basis.

Consent:

When you submit your application with Topcatalogues.co.uk, we process your personal data on the basis that you have provided your consent to be contacted by Pathfind Media Ltd and our panel of mobile phone contract providers.

You can withdraw your consent by using the opt-out methods provided within all communications. This will come in the form of an unsubscribe function for email and an opt-out function for SMS (this will usually take the form of entering the number you wish to opt-out at mobgo.co, our in-house opt-out service). You can also contact our Data Protection Officer at info@pathfind.co or using the contact details stated in section 15 / 16. If you change your mind about agreeing to us processing your personal data, this will not have any effect on the lawfulness of any processing we have carried out before you changed your mind.

Legitimate Interest:

We have a legitimate interest in processing your data (i.e. to share your phone contract enquiry with our panel of mobile phone providers) to obtain the mobile phone deal you have applied for.

You can object to us processing your data in this way by contacting our Data Protection Officer at info@pathfind.coor using the contact details stated in section 15 / 16.

3. How you contact us

If at any time you need to contact us then you can do so by emailing info@pathfind.co or by mail at the address in section 16.

4. How we keep you informed

We may want to make contact with you at some point in order to keep you informed regarding offers on products or services which we think you may find of interest, this contact will be made via email and SMS, .

5. Obtaining Personal Data / Information

1. You are free to access and browse our website Topcatalogues.co.uk  at your convenience and do not have to provide any personal information/data, however we would like to refer you to the 'Cookies' section set out within this privacy policy.
2. The information/data that we collect from you may include the following details:
   1. Name
   2. Email address (if applicable)
   3. Telephone number (home, mobile)
   4. IP Address
   5. GCLID - Google Click ID: This is a unique but non-personal identifier generated when you click a Google search ad. When you submit an enquiry, your GCLID is recorded and used to track that conversion with Google. This helps us make our marketing relevant to future customers but not personalised to you.
   6. What you do on our website; the results of this will be used to show Topcatalogues.co.uk examples of which parts of our website are most and least used (please refer to 'Cookies' section)

If you apply with us and have a question about our services, or alternatively choose to send an email to info@pathfind.co we may also collect the above personal information/data in this instance in order for us to respond to your enquiry.

6. Customer Communication

Unless the customer states otherwise we will contact the customer via means of SMS and email to provide information and alerts relating to our services and our associate companies.

Ensuring your personal details & or preferences are kept up to date:

It is your responsibility to ensure that any information we have on record for you is kept up to date and correct. If you do require any of your information to be updated then please contact us as soon as possible so we can ensure it is corrected.

If you require your preferences to be updated then please contact our Compliance Manager as soon as possible (details set out below).

7. What personal information do we collect?

We collect personal information about you when you give this to us when applying for a mobile phone product online. This might be to obtain comparative quotes for mobile phone, SIM only or other products relevant to your use of our service. In the course of providing the services to you, we may also store information about how you use our sites, for example, the pages viewed, the website from which you came to visit our Sites, changes you make to information you supply to us, details of the quotes you request and your applications.

In order to provide you with a mobile phone offer we will collect personal information. By proceeding with obtaining a deal you give your explicit consent to such information being processed by us and our third-party providers for the purposes stated in this Privacy Policy.

We will store the information you provide and may use it to pre-populate fields on the Sites and to make it easier for you to use the Sites when making return visits

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law.

8. Who do we share your personal information with?

When you complete an enquiry, you consent to us disclosing your personal information to the following parties:

Topcatalogues.co.uk  and Pathfind Media Ltd: (i) to communicate with you, including sending you information about products and services which may be of interest to you; (ii) to speed up form filling, or to personalise, or improve your experience on its website, mobile applications or other similar devices, channels or applications; or (iii) in accordance with its privacy policy.

Our channel operators: whilst the majority of the channels on our Sites are run by us, some of our channels are designed and maintained for us by our third party service providers. We may receive your personal information from these service providers and use it in accordance with section 4 above. We will only use the personal information we receive from third parties where the relevant third party can show that it was collected and processed with your consent;

Regulatory bodies for the purposes of compliance monitoring;

Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses):

1. if required or permitted to do so by law;
2. if required to do so by any court or any other applicable regulatory, compliance, Governmental or law enforcement agency;
3. if necessary in connection with legal proceedings or potential legal proceedings; and/or
4. in connection with the sale or potential sale of all or part of our business.

If you choose to enter a phone contract with any of our mobile phone partners, the information you have provided to us, together with any further information requested by, and supplied by you or us to the third party provider, will be held by the partner for the purposes set out in that partners's privacy policy. Therefore, you are strongly advised to read your chosen partner's privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into a mobile phone contract. We have no responsibility for the uses to which a partner puts your personal information

By submitting an enquiry form on our site, you confirm that all of the information provided is true and accurate.

9. How do we use your personal information?

We may use your personal information:

1. to enable you to access and use the Services;
2. to personalise and improve aspects of our Services;
3. for research, such as analysing market trends and customer demographics;
4. to communicate with you, including some or all of the following:
   1. sending you a confirmation email - when you submit an enquiry with us, you will automatically be sent confirmation of your enquiry by email or SMS so that you have a record of it;
   2. sending you information on mobile phone deals or similar in order to provide our service to you
      
      This is a list of the partners we work with in order to fulfil our offer of supplying you with a mobile phone offer and/or broadband. We may send you promotional messages via email and SMS under the grounds of legitimate interest:
   • Three Mobile
   • Vodafone
   • BT Mobile
   • Voxi
   • Smarty
   • Buymobiles.net
   • Mobiles.co.uk
   • Yes Catalogue
   • Sunshine Mobile
   • Accepted Mobile
   • Fonehouse
5. to process an application between you and a third party;
6. to track applications, which may involve us sharing data with your product provider relating to the product(s) you have chosen. Your product provider may also send us information they hold relating to the product(s) you have chosen for this purpose;
7. to match our data with data from other sources - we may validate and analyse your information and, in some cases, match it against information that has been collected by a third party to ensure that the information we hold about you is as accurate, consistent and as well-organised as possible.

We may provide your personal information (email or phone) to Google Ads for the purposes of using "Customer Match" - in order to better find customers. This is not personalised advertising not remarketing to you.

10. What cookies do we use?

Cookies and Web Beacons

This section sets out our use of Cookies when you use our sites. Please read it carefully as it explains how we and third parties may make use of your data collected by such Cookies. If you wish to understand how we make use of your data, more generally please refer to section 8.

We use a single first party cookie, named 'PHPSESSID'. This cookie is vital for the operation of the website, as it allows us to track different page loads to yourself, which allows the form and application process to work.

To find out more about accepting or refusing cookies please visit www.allaboutcookies.org.

We also use Google Analytics to collect non-personally identifiable information, in aggregate form, to understand website/page visit volumes in terms of source, geography, browser, etc.

Google Analytics employs a software technology called web beacons, that help us better manage content on our site by informing us what content is effective. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users or responses to emails. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons cannot be disabled in same manner as cookies may. We do not tie the information gathered by web beacons to our customers' personally identifiable information.

Cookies used by Google Analytics:

Google Analytics is a simple, easy-to-use tool that helps website owners measure how users interact with website content. As a user navigates between web pages, Google Analytics provides website owners JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to "remember" what a user has done on previous pages / interactions with the website.

Important: Read the Google Analytics privacy document for more details about the data collected by Google Analytics.

Google Analytics supports three JavaScript libraries (tags) for measuring website usage: gtag.js, analytics.js, and ga.js. The following sections describe how each use cookies.

Facebook (Visitor action pixel)

We use the "visitor action pixels" from Facebook Inc (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook")) on our website.

This allows user behaviour to be tracked after they have been redirected to the provider's website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook's Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.

Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation ( https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

Privacy Policy for the use of Instagram

On our websites functions of the service Instagram are embedded. These functions are offered by the Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged in to your Instagram account, you can link contents of our websites to your Instagram profile by clicking the Instagram button. By this ,Instagram will associate the visit of our websites with your user account. We would like to point out that we, as providers of these websites, do not obtain knowledge about the contents of transmitted data as well as their use by Instagram.

For further information, please review the Privacy Policy of Instagram: http://instagram.com/about/legal/privacy/

Cookie settings

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that by disallowing cookies some functionality on the site may be restricted.

11. How secure is our site and what steps do we take to keep you safe?

Our websites are secured by Fasthosts and keeping information about you secure is very important to us. However, no data transmission over the internet can be guaranteed to be totally secure.

We do our best to keep the information you disclose to us secure. However, we can't guarantee or warrant the security of any information which you send to us, and you do so at your own risk. By using our Sites you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

12. Rights of access to your personal information

You have certain rights under the General Data Protection Regulations . For example, we will always let you have a copy of the personal information we hold about you, if you request it from us in writing.

• Right to be informed when we collect your data we have to tell you what we are going to do with it primarily though this Privacy Policy and within the opt in /consent statement.
• Right to Object - because you have asked us to help you find a financial product or service, we need to process the personal information you give us to enable us to find the best product or service available amongst our panel of mobile phone providers. You can object to this processing at any time by sending us an email at info@pathfind.co , or by writing to the Customer Services Team at Pathfind Media Ltd, 2 Wellington Place, Leeds, LS1 4AP. We will action any request you make promptly, although this will mean that we will not be able to help you find the financial product or service that you asked us to search for.
• Right of Access - you can ask us at any time to confirm whether we hold your personal information, and if so, you can access it by writing to us at: Compliance Department. Pathfind Media Ltd, 2 Wellington Place, Leeds, LS1 4AP or by sending us an email at info@pathfind.co
• Right to rectification - if we hold personal information about you that is inaccurate, you can ask us to correct it, and we will do this as quickly as possible.
• Right to erasure - if it is no longer necessary for us to hold your personal information bearing in mind the reason why you provided it to us, you can ask us to delete it. If you ask us to do this, we will delete your personal information as soon as possible although this will mean that we may not be able to help you find the financial product or service that you asked us to search for.
• Right to restrict our use of your information - you can ask us to restrict our processing of your personal information if you think for example that the personal information you gave us is inaccurate. This may mean that we may not be able to help you find the financial product or service that you asked us to search for.
• Right to data portability - this gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly be used if you were switching banks, insurance companies and utility companies.
• Right to complain to the Information Commissioner's Office (ICO) - we will try to resolve any complaint that you may have in relation to data protection issues. If you are not happy with our final response you have the right to have your complaint dealt with by the ICO. Please refer to our Complaints section How To Make a Complaint below for further information.

To make enquiries and/or exercise any of your rights set out in this Privacy Policy please contact our Customer Services Team at info@pathfind.co.

13. How long will we retain your personal information for?

The amount of time we retain your information for will depend on the reason it was provided:

• If you request to opt out of marketing, we will still need to retain your information in order to evidence your preferences.
• We will need to retain, for a minimum period of 6 years, any information relating to applications you have entered into on our website. This period will commence once your relationship with us has ended. We need to keep your information for this length of time to assist with any potential future complaints.

16. How to make a complaint

Topcatalogues.co.uk always aim to be fair and honest in everything we do, so if you have a complaint about any aspect of our service we're keen to resolve it as quickly as possible. You can contact us in any of the following ways:
By Post:
Complaints Department, Topcatalogues.co.uk , 2 Wellington Place, Leeds, LS1 4AP
By Email: info@pathfind.co