Privacy Policy and cookies

Across MONY Group, we have a number of privacy policies which set out how we collect your personal information and use it. Please note that this Privacy Policy only relates to MONY Group plc.

If you are a customer or user of our customer-facing brands, MoneySuperMarket, MoneySavingExpert, TravelSupermarket, Decision Tech or Quidco, please refer to the privacy policies on their respective websites.

MONY Group plc (‘MONY Group plc’, ‘us’ or ‘we’) respects the privacy of every individual whose personal information it handles. This Privacy Policy explains how we collect, store and use personal information.


Controller

For the purposes of applicable legislation, including the Data Protection Act 2018 and the UK General Data Protection Regulation (‘UK GDPR’), as amended or supplemented (‘Data Protection Laws’), MONY Group plc is the controller of your personal information. The controller's representative for the purposes of this Privacy Policy is MONY Group plc's Company Secretary, who can be contacted using the contact details set out under "MONY Group plc Data Privacy Contacts".


Shareholders (including beneficial shareholders)

The personal details of all our shareholders (both current and former shareholders and whether legal or beneficial) who hold shares directly, or details of the nominee accounts in which some retail and institutional shareholders hold their shares, are held and maintained on our behalf by our Registrar.

We collect personal information about you, including:

  • your name;
  • your address;
  • details of your past and present holdings of shares and/or interests in shares in MONY Group plc, whether you hold or held these as legal owner or have or had a beneficial interest in them;
  • details of how you have in the past exercised, or intend in the future to exercise, your voting rights attached to shares in MONY Group plc;
  • your bank and building society account details into which dividends and other income or capital returns on your shares have in the past, or should in the future, be paid; and
  • your contact details, such as email addresses and telephone numbers, where you have provided these to us.

Shareholder information is collected and maintained on our behalf for the purposes of:

  • complying with our regulatory and legal obligations including those that require us to keep records and returns about the shareholdings in MONY Group plc(e.g. registering share transactions and processing administrative changes to shareholder records) and complying with disclosure requirements imposed or enforced by governmental authorities and regulatory agencies, including law enforcement agencies and tax authorities;
  • complying with our contract(s) with you, as set out in our Articles of Association and/or in any share scheme or plan trust deed or rules, including giving you the information and communicating with you in the ways referred to therein;
  • communicating with shareholders and disseminating information about MONY Group plc (including the mailing, in physical or electronic format, of Annual Reports, AGM or EGM notices or proxy cards, or communications in relation to other corporate actions and answering questions you ask of us);
  • enabling us to enforce or defend our legal rights, including by bringing or defending legal claims that may be made by or against MONY Group plc in relation to your shareholdings or interests in shares;
  • enabling our Registrar to offer an online web portal which shareholders can use to access and manage their shareholdings in MONY Group plc online and provide information on shareholder services available to them;
  • facilitating the payment of dividends; and
  • facilitating Dividend Reinstatement Plans (‘DRIP’) instructions.

The personal information we hold about shareholders may be shared with:

  • companies who process personal information on MONY Group plc's behalf, such as our shareholder Registrar, Link Market Services Limited   (trading as Link Asset Services), and providers of cloud hosting solutions;
  • third party suppliers and service providers to MONY Group plc, for example professional advisers, such as accountants, lawyers, proxy advisers or other consultants and third parties who are used by us to perform processing activities, such as software providers and payment service providers;
  • the FCA, the London Stock Exchange or any other relevant regulatory authority or exchange in the UK or overseas and with the courts or other parties to legal proceedings pursuant to court rules and orders;
  • subsidiaries of MONY Group plc, for example where they assist us in complying with our legal obligations to you and/or managing our relationship with you; and
  • any person entitled to inspect the share register in accordance with legal or regulatory requirements.

In accordance with Data Protection Laws, our legal basis for collecting and storing personal information about you is because we have legal obligations to do so and it is necessary to perform our contract(s) with you as a shareholder and/or holders of interests in shares in MONY Group plc. Otherwise, we process your personal information on the basis that such processing is necessary for our legitimate interests in operating and carrying out administrative functions relating to our shareholders and ensuring effective communications with shareholders.

  1. Where we process your personal information only on the basis of our legitimate interest, you have the right to object to that use. However, we do not have to stop processing personal information where we have compelling grounds that override your interests, or where we need to process your personal information in order to establish, exercise or defend legal claims.

Where we use your personal information because we have a legal obligation to do so or perform a contract with you, there is no right to object.

Personal information of suppliers, professional advisers and business contacts

If you are a supplier to MONY Group plc, one of its professional advisers or have had contact with MONY Group plc, for example through emailing us or meeting a MONY Group plc representative, we may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details. We will collect and store this personal information for the purposes of:

  • managing our business relationship with the organisation that you represent, including communicating with your organisation and negotiating, concluding and performing business transactions with your organisation, such as procuring products and/or services from your organisation, partnering with your organisation or appointing your organisation as our agent or your organisation appointing us its agent;
  • managing our business arrangements, including to assess and report on the effectiveness of our business relationship with your organisation;
  • ensuring compliance with applicable laws and regulations to which we are subject, including those which require us to keep records of business transactions with your organisation;
  • ensuring compliance with contractual obligations which we have assumed to your organisation, including those which require us to notify your organisation of matters; and
  • conducting any audit or investigation into our business dealings with your organisation, responding to any regulatory investigations commenced (or likely to be commenced) into a MONY Group company in relation to such business dealings or managing any legal claims brought (or likely to be brought) by or against a Moneysupermarket Group company in relation to such business dealings.

The personal information we hold about suppliers, professional advisers and business contacts may be shared with:

  • third parties where we are legally obliged to do so, for example to government bodies and regulatory authorities and to the courts and parties to legal proceedings pursuant to court rules and orders;
  • third party suppliers and service providers to MONY Group plc, for example professional advisers, such as accountants, lawyers, or other consultants and third parties who are used by us to perform processing activities, such as software providers and payment service providers; and
  • other companies in the MONY Group.

In accordance with data protection laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.

Save where we process your personal information to comply with a legal duty, we process your personal information on the basis of our legitimate interests. Our legitimate interests are to achieve all those purposes above that do not relate to complying with a legal duty.

Where we process your personal information only on the basis of our legitimate interest, you have the right to object to our use of your personal information. However, we do not have to stop processing personal data where we have compelling grounds that override your interests, or where we need to process your data in order to establish, exercise or defend legal claims.

Where we process your personal data because we have a legal obligation to do so, there is no right to object.

Visitors to the MONY Group plc website

When you visit MONY Group plc's website, we may automatically collect the following information:

  • technical information including web usage information (e.g. IP address), browser type and version, time zone setting, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (‘URLs’) clickstream to, through and from our website, time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods to browse away from the page (see “Cookies” and “Google Analytics”).