Last updated: December 2024
1. Introduction
This Privacy Policy describes how Pricentia (hereinafter “Controller” or “we”) processes the personal data of users who visit the website pricentia.com (hereinafter “Website”) and use our services.
Pricentia is a smart assistant that helps users find the best deals across financial services, energy, telecoms, and insurance. Our service operates through:
- Informative website for service discovery
- AI assistant via Telegram/WhatsApp for personalised conversations
- Email for delivering offers and documentation
This policy is provided in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and supplements our Cookie Policy.
2. Data Controller
| Controller | Pricentia |
| [email protected] | |
| Website | pricentia.com |
For any enquiries regarding the processing of your personal data, you can contact us at the email address provided.
3. Categories of Data Processed
3.1 Navigation Data
The IT systems and software procedures used to operate the Website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.
This data includes:
| Data | Description |
|---|---|
| IP address | Device connection identifier |
| Requested URLs | Pages visited on the Website |
| Request time | Date and time of access |
| HTTP method | Type of request to the server |
| Response code | Request outcome |
| User Agent | Browser and operating system used |
| Referrer | Source website (if present) |
This data is used to:
- Ensure proper Service functionality
- Compile anonymous usage statistics
- Verify security and prevent abuse
3.2 Data Provided Voluntarily
When using our services, you may voluntarily provide us with the following data:
Contact Data
| Data | Purpose |
|---|---|
| Phone number | To contact you via Telegram/WhatsApp |
| Email address | To verify your identity in order to protect your data and send you offers and communications |
| Name | To personalise communication |
Data Collected During Conversations
When you interact with our AI assistant on WhatsApp or Telegram, we may collect:
- Preferences and needs expressed during the conversation
- Information about the product/service you are interested in
- Answers to questions posed by the assistant to personalise offers
Important: We never collect sensitive data (health, political, religious, or sexual orientation) unless strictly necessary for the requested service and only with your explicit consent.
3.3 Data Collected via Cookies
For detailed information about cookies and tracking technologies used, please see our Cookie Policy.
4. Purposes and Legal Basis for Processing
Below are the purposes for which we process your personal data and the relevant legal basis:
4.1 Necessary Purposes (without consent)
| Purpose | Legal Basis | Description |
|---|---|---|
| Service delivery | Contractual necessity (Art. 6.1.b UK GDPR) | Providing information and services requested via the Website, WhatsApp or Telegram |
| Request management | Contractual necessity (Art. 6.1.b UK GDPR) | Responding to your enquiries and managing your quote requests |
| Legal compliance | Legal obligation (Art. 6.1.c UK GDPR) | Fulfilling obligations required by applicable law |
| Website security | Legitimate interest (Art. 6.1.f UK GDPR) | Preventing fraud, cyberattacks and ensuring security |
4.2 Consent-Based Purposes
| Purpose | Legal Basis | Description |
|---|---|---|
| Direct marketing | Consent (Art. 6.1.a UK GDPR) | Sending promotional communications about Pricentia products and services |
| Profiling | Consent (Art. 6.1.a UK GDPR) | Analysing your preferences to offer personalised content and offers |
| Analytics cookies | Consent (Art. 6.1.a UK GDPR) | Analysing Website usage to improve user experience |
| Marketing cookies | Consent (Art. 6.1.a UK GDPR) | Showing relevant advertisements on third-party platforms |
Note on consent: You can withdraw consent at any time without affecting the lawfulness of processing based on consent given before withdrawal.
5. How We Process Data
Personal data is processed using automated tools for the time strictly necessary to achieve the purposes for which it was collected.
Specific security measures are adopted to prevent:
- Data loss
- Unlawful or improper use
- Unauthorised access
Processing takes place at the Controller’s premises and in any other location where the parties involved in processing are located.
6. Data Sharing and Disclosure
6.1 Categories of Recipients
Your personal data may be shared with:
| Category | Role | Examples |
|---|---|---|
| IT service providers | Data processors | Hosting, cloud, maintenance |
| Messaging platforms | Data processors | WhatsApp (Meta), Telegram |
| Email marketing services | Data processors | Platforms for sending communications |
| Analytics services | Data processors | Google Analytics |
| Consultants | Independent controllers | Legal, tax advisors |
| Authorities | Independent controllers | Upon request from competent authorities |
6.2 Messaging Platforms (WhatsApp/Telegram)
When you contact us via Telegram/WhatsApp or Telegram, your messages and data are also subject to the privacy policies of these platforms:
6.3 No Sale of Data
We do not sell, rent, or transfer your personal data to third parties for independent marketing purposes.
7. International Data Transfers
Some of our service providers may process your data outside the United Kingdom.
In these cases, we ensure that transfers occur:
- To countries with an adequacy decision
- Based on Standard Contractual Clauses (SCCs) approved by the UK ICO
- With additional security measures where necessary
| Provider | Country | Safeguard |
|---|---|---|
| Google LLC | USA | UK Extension to EU SCCs |
| Meta Platforms | USA | UK Extension to EU SCCs |
| Cloudflare | USA | UK Extension to EU SCCs |
8. Data Retention Period
Personal data is retained for the time strictly necessary for the purposes for which it was collected:
| Data Type | Retention Period |
|---|---|
| Navigation data | 90 days |
| Contact data (forms) | 24 months from collection or until consent withdrawal |
| WhatsApp/Telegram conversations | 24 months from last interaction |
| Marketing data | Until consent withdrawal |
| Profiling data | 24 months, then anonymised |
| Accounting/tax data | 7 years (legal requirement) |
At the end of the retention period, data will be deleted or irreversibly anonymised.
9. Your Rights
Under Articles 15-22 of the UK GDPR, you have the right to:
| Right | Description |
|---|---|
| Access (Art. 15) | Obtain confirmation of processing and access your data |
| Rectification (Art. 16) | Correct inaccurate or incomplete data |
| Erasure (Art. 17) | Request deletion of your data (“right to be forgotten”) |
| Restriction (Art. 18) | Restrict processing of your data in certain cases |
| Portability (Art. 20) | Receive your data in a structured, readable format |
| Object (Art. 21) | Object to processing based on legitimate interest or direct marketing |
| Withdraw consent (Art. 7) | Withdraw consent at any time |
How to Exercise Your Rights
You can exercise your rights:
- By email: [email protected]
- Via the link “Manage preferences” in the Website footer (for cookies)
We will respond to your request within 30 days, unless the case is particularly complex.
Complaint to the Supervisory Authority
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
- Website: ico.org.uk
- Helpline: 0303 123 1113
- Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
10. Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. Changes will be published on this page with an updated “Last updated” date.
In case of substantial changes, we will notify you via:
- Visible notice on the Website
- Email (if you have provided your address)
We recommend checking this page periodically.
11. Cookie Policy
For detailed information about the cookies used, their purposes and how to manage your preferences, please see our Cookie Policy.
12. Contact Us
For any questions regarding this Privacy Policy or the processing of your personal data:
Email: [email protected]
13. Legal References
| Legislation | Description |
|---|---|
| UK GDPR | UK General Data Protection Regulation |
| DPA 2018 | Data Protection Act 2018 |
| PECR | Privacy and Electronic Communications Regulations 2003 |
| ICO Guidance | ICO Guidance on data protection and privacy |