Privacy Policy

UNLIMITED respects your privacy and is committed to protecting your
personal data. This privacy notice will inform you as to how we look after
your personal data and tell you about your privacy rights and how the law
protects you.

This privacy notice is provided in a layered format so you can click
through to the specific areas set out below. Please also use the Glossary
to understand the meaning of some of the terms used in this privacy

1. Important information and who we are
Purpose of this privacy notice

This privacy notice aims to give you information on how UNLIMITED collects
and processes your personal data through your use of this website,
including any data you may provide through this website when you contact

This website is not intended for children and we do not knowingly collect
personal data relating to children.

It is important that you read this privacy notice together with any other
privacy notice or fair processing notice we may provide on specific
occasions when we are collecting or processing personal data about you so
that you are fully aware of how and why we are using your data. This
privacy notice supplements the other notices and is not intended to
override them.

Data Controller

UNLIMITED* is the data controller and responsible for processing your
personal data (collectively referred to as ‘Unlimited Group’, ‘we’, ‘us’,
or ‘our’ in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for
overseeing questions in relation to this privacy notice. If you have any
questions about this privacy notice, including any requests to exercise
your legal rights, please contact the DPO using the details set out below.

Contact details
Our full details are:
Full name of legal entity: See below for subsidiary, however operating
parent is Digital Unlimited Group Limited
Name or title of DPO: Data Protection Officer
Postal address London: First Floor, Orion House, 5 Upper St Martin’s Lane,
London WC2H 9EA

You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data
protection issues ( We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so please
contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 3 February 2022

2. The data we collect about you

Personal data, or personal information, means any information about an
individual from which that person can be identified, directly or
indirectly. It does not include information from which a person cannot be
identified (anonymous data).

We may collect, use, store and transfer different kinds of personal data
about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last
    name, username or similar identifier, marital status, title, date of
    birth and gender
  • Contact Data includes billing address, delivery
    address, email address and telephone number/s
  • Technical Data includes internet protocol (IP) address,
    your login data, browser type and version, time zone setting and
    location, browser plug-in types and versions, operating system and
    platform and other technology on the devices you use to access this
  • Usage Data Data includes information about how you use
    our website, products and services.
  • Marketing and Communications Data includes your
    preferences in receiving marketing from us and our third parties and
    your communication preferences.

We also collect, use and share Aggregated Data such as statistical or
demographic data. Aggregated Data may be derived from your personal data
but is not considered personal data in law as this data does not directly
or indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific
website feature. However, if we combine or connect Aggregated Data with
your personal data so that it can directly or indirectly identify you, we
treat the combined data as personal data which will be used in accordance
with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health and genetic and biometric data).
Nor do we collect any information about criminal convictions or offences.

Where we need to collect personal data by law, or under the terms of a
contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are
trying to enter with you (for example, to provide you with goods or
services). In this case, we may have to cancel a product or service you
have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We may use different methods to collect data from and about you including

Direct Interactions. You may give us your identity and
contact data by filling in forms or by corresponding with us by post,
phone, email or otherwise. This includes personal data you provide when

  • Apply for our products or services;
  • Request marketing to be send to you;
  • Give us feedback

Automated technologies or interactions. As you interact
with our website, we may automatically collect technical data about your
equipment, browsing actions and patterns. We collect this personal data
(including IP Address) by using cookies, server logs and other similar
technologies. Please refer to our cookie policy for further details which
you will find on the cookie banner when you arrive at our website.

Third parties or publicly available sources. We may
receive personal data about you from various third parties as set out

  • Technical data from analytics providers such as Google based outside the
    UK and EU
4. How we use your personal data

We will only use your personal data when the law allows us to. Most
commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third
    party) provided that your interests and fundamental rights are not
    overridden by those interests. We have performed a Legitimate Interests
    Assessment where this lawful basis applies.
  • Where we need to perform the contract we are about to enter into or have
    entered into with you.
  • Where we need to comply with a legal or regulatory obligation

Generally, we do not rely on consent as a lawful basis for processing your
personal data other than in relation to sending third-party direct
marketing communications to you via email or text message. You have the
right to withdraw consent to marketing at any time by contacting us at the
email address given above.

Purposes for which we will use your personal data

To use data analytics to improve our website,
products/services, marketing, customer
relationships and experiences

(b) Usage
Necessary for our legitimate interests (to define types
of customers for our products and services, to keep
our website updated and relevant, to develop our
business and to inform our marketing strategy)
Other survey opportunities from third-parties

We may use your Identity, Contact, Technical, Usage and Profile Data to
form a view on what we think you may want or need, or what may be of
interest to you. This is how we decide which products, services and offers
may be relevant for you.

Opting out

We provide the opportunity to withdraw your participation from any surveys
you are invited to take part in.


When you visit our website you will be given the option to consent to
non-essential cookies using a cookie banner. Some cookies are essential to
allow full access to the website and in order for it to function properly.
If you disable or refuse cookies, please note that some parts of this
website may become inaccessible or not function properly. For more
information about the cookies we use, please see our
Cookie Policy.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for
the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of
    our business or our assets. Alternatively, we may seek to acquire other
    businesses or merge with them. If a change happens to our business, then
    the new owners may use your personal data in the same way as set out in
    this privacy notice. We require all third parties to respect the
    security of your personal data and to treat it in accordance with the
    law. We do not allow our third-party service providers to use your
    personal data for their own purposes and only permit them to process
    your personal data for specified purposes and in accordance with our
6. International transfers

The majority of external data storage used by UNLIMITED is located within
the UK and EU, where possible we ensure UK or EU data centres are used. We
use Office 365 and Confirmit servers located within the EEA. To the extent
we transfer data outside of the EEA we will ensure that the appropriate
safeguards are in place e.g. where personal data is transferred to third
parties in the United States, we implement an international data transfer
agreement following a risk assessment.

7. Data security

We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access to
your personal data to those employees, agents, contractors and other third
parties who have a business requirement to access it. They will only
process your personal data on our instructions and they are subject to a
duty of confidentiality.

We have put in place procedures to deal with any suspected personal data
breach and will notify you and any applicable regulator of a breach where
we are legally required to do so.

8. Data retention
How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying
any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we
consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the
applicable legal requirements.

Details of retention periods for different aspects of your personal data
are available in our retention policy which you can request from us by
contacting us.

In some circumstances you can ask us to delete your data: see Request
erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can
no longer be associated with you) for research or statistical purposes in
which case we may use this information indefinitely without further notice
to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in
relation to your personal data. See below to find out more about these

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data (where applicable).
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above,
please contact us

No fee usually required

You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a reasonable fee
if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these

What we may need from you

We may need to request specific information from you to help us confirm
your identity and ensure your right to access your personal data (or to
exercise any of your other rights). This is a security measure to ensure
that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in
relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this case,
we will notify you and keep you updated.

10. Glossary

Legitimate Interest means using your data in ways you
would reasonably expect where it is necessary for us to use your data
without giving you full control upfront.

We make sure we consider and balance any potential impact on you (both
positive and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless
we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific
activities by contacting us.

Performance of Contract means processing your data where
it is necessary for the performance of a contract to which you are a party
or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means
processing your personal data where it is necessary for compliance with a
legal or regulatory obligation that we are subject to.

Internal Third Parties

Other companies in UNLIMITED acting as joint controllers or processors and
who are based in the UK and provide IT and system administration services
and undertake leadership reporting.

External Third Parties
  • Service providers acting as processors based in United Kingdom or EU who
    provide IT and system administration services.
  • Professional advisors acting as processors including lawyers, bankers,
    auditors and insurers based in the United Kingdom who provide
    consultancy, banking, legal, insurance and accounting services.
  • HM Revenue and Customs, regulators and other authorities acting as
    processors based in the United Kingdom who require reporting of
    processing activities in certain circumstances.

You have the right to:

Request access to your personal data (commonly known as a
data subject access request”). This enables you to receive a copy of the
personal data we hold about you and to check that we are lawfully
processing it.”

Request correction of the personal data that we hold
about you. This 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.

Request erasure of your personal data. This enables you
to ask us to delete or remove personal data where there is no good reason
for us continuing to process it. You also have the right to ask us to
delete or remove your personal data where you have successfully exercised
your right to object to processing (see below), where we may have
processed your information unlawfully or where we are required to erase
your personal data to comply with local law. Note, however, that we may
not always be able to comply with your request of erasure for specific
legal reasons which will be notified to you, if applicable, at the time of
your request.

Object to processing of your personal data where we are
relying on a legitimate interest (or those of a third party) 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 fundamental
rights and freedoms. You also have the right to object where we are
processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to
process your information which override your rights and freedoms.

Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data
in the following scenarios: (a) if you want us to establish the data’s
accuracy; (b) where our use of the data is unlawful but you do not want us
to erase it; (c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims;
or (d) you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a
third party. We will provide to you, or a third party you have chosen,
your personal data 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.

Withdraw consent at any time where we are relying on
consent to process your personal data. However, this will not affect the
lawfulness of any processing carried out before you withdraw your consent.

*Note UNLIMITED is a group of companies of which the controller hereunder
is the UNLIMITED brand website you are currently on:

Nelson Bostock or Fever: Nelson Bostock Group Limited
(company number 2143374)

Health: Health Unlimited Limited (company number

TMW or TMW Business: Tullo Marshall Warren Limited
(company number 1332638)

Realise or Walnut: Walnut Unlimited Limited (company
number 1317137)

UNLIMITED: Digital Unlimited Group Limited (company
number 210505)