Privacy Policy
1. Who we are and the scope of this policy
ToucanChoose is a trading name of Codique Ltd, a company registered in England and Wales under company number 10325352. Our registered office is 9 Clifton Avenue, Brymbo, Wrexham, LL11 5FS.
For the personal information that we decide how and why to use, Codique Ltd is the “controller” under applicable United Kingdom data-protection law. References in this policy to “ToucanChoose”, “we”, “us” or “our” mean Codique Ltd trading as ToucanChoose.
This policy explains how we collect, use, disclose and protect personal information when you visit or use toucanchoose.com, contact us, use our comparison tools, create or use an account, save or compare offers, or follow a link from our website to a third-party provider.
This policy applies to users in the United Kingdom. It should be read with our website Terms of Use and our separate Cookie Policy.
2. Our role as a comparison and referral website
ToucanChoose is a comparison and referral website. We present information about products and services offered by participating third-party providers so that users can review and compare options and decide what may suit their needs.
We do not supply, install, operate, bill for or support the broadband, energy or other third-party services displayed on our website. When you choose to continue with an offer, you may be redirected to the provider’s own website. Any application, eligibility check, availability check, order, contract, payment or service relationship is then between you and that provider, subject to its own terms and privacy notice.
We may not compare every provider or every offer available in the market. The providers and offers shown may depend on our commercial relationships, data feeds, technical availability, location and other factors.
3. Personal information we may collect
The personal information we collect depends on how you use the website. It may include the following categories:
| Category | Examples |
|---|---|
| Identity and contact information | Your name, email address, telephone number and any other contact details you choose to provide. |
| Account information | If accounts are available: your account email, login and security information, saved preferences, favourites, comparisons and account settings. |
| Comparison and preference information | The filters, providers, products, packages, prices, speeds, features and offers you view, shortlist, save or compare. |
| Location and availability information | A postcode, address or general location entered into an availability, address-search or comparison tool. |
| Communications | Messages, enquiries, complaints, feedback and correspondence you send to us, including any information contained in attachments. |
| Technical and usage information | Internet Protocol address, device and browser type, operating system, pages viewed, referral source, timestamps, interaction data, diagnostics and security logs. |
| Affiliate and referral information | Referral or click identifiers, the provider or offer selected, referral timestamps, campaign information and limited transaction or commission-status information received through an affiliate network. |
| Cookie and consent information | Your cookie choices, consent status and information generated by cookies or similar storage and access technologies, as described in our Cookie Policy. |
Please do not send sensitive information
We do not ask users to provide special-category information such as health, biometric, religious, political or sexual-orientation information. Please avoid including sensitive personal information in general enquiries unless it is genuinely necessary.
4. How we collect personal information
We may collect personal information:
- directly from you when you complete a form, contact us, create or use an account, save or compare an offer, make a complaint, subscribe to communications or otherwise interact with us;
- automatically from your device when you browse the website, subject to your cookie choices and applicable law;
- from affiliate networks such as Awin when a referral, qualifying action or transaction is recorded or reported;
- from participating providers and data suppliers, for example offer information, availability data or limited referral-status information; and
- from service providers that help us operate, protect and measure the website.
5. How and why we use personal information
We only use personal information where we have a lawful basis. The basis depends on the purpose and the circumstances. The table below summarises the main purposes we currently expect to apply.
| Purpose | How we use the information | Lawful basis |
|---|---|---|
| Operate the website and comparison tools | Display offers, apply filters, create shortlists, save comparisons and provide requested site functions. | Legitimate interests; contract where an account service is provided. |
| Respond to users | Answer enquiries, provide support, respond to feedback and deal with complaints. | Legitimate interests; steps requested before a contract where relevant. |
| Manage accounts | Register, authenticate and maintain accounts, preferences and saved information. | Contract; legitimate interests for security and administration. |
| Check location or availability | Use a postcode, address or location to show relevant availability or products where this feature is offered. | Steps requested by you; legitimate interests. |
| Track affiliate referrals | Attribute referrals and qualifying transactions, calculate commissions, produce reports and resolve tracking enquiries. | Consent where required for cookies or similar technologies; legitimate interests for limited referral administration and reporting. |
| Improve the website | Understand usage, diagnose errors, test features and improve usability, content and performance. | Consent for non-essential analytics technologies; legitimate interests for aggregated, essential or security-related information. |
| Security and fraud prevention | Protect users, accounts, systems and commercial partners; investigate misuse and suspicious activity. | Legitimate interests; legal obligation where applicable. |
| Legal and business administration | Maintain records, comply with law, manage disputes, enforce rights and support audits, insurance or corporate transactions. | Legal obligation; legitimate interests. |
| Marketing, where used | Send requested updates or marketing and measure their performance. | Consent, or legitimate interests where the law permits and an opt-out is provided. |
Where we rely on legitimate interests, those interests may include operating and improving a useful comparison service, funding the service through affiliate referrals, keeping the website secure, understanding business performance, protecting our legal rights and responding to users. We consider whether our interests are proportionate and whether your rights and interests override them.
Where we rely on consent, you may withdraw that consent at any time. Withdrawal does not make earlier processing unlawful.
6. Affiliate referrals and Awin
ToucanChoose may earn commission when you follow an affiliate link and complete a qualifying action or purchase with a participating provider. This helps fund the website. You are not charged a fee by ToucanChoose for using the comparison service.
We use the Awin affiliate network to help operate this referral model. When you click a relevant link, Awin may use cookies, referral identifiers, journey tags, device information or other tracking methods, subject to applicable law and your cookie choices. This allows Awin, ToucanChoose and the provider to understand that a user was referred from our website and whether a qualifying transaction occurred.
Affiliate information is usually pseudonymous rather than information that directly names you. Depending on the provider and campaign, it may include a click or referral identifier, the advertiser campaign, the publisher, the country, the device used and limited transaction information such as order value, product type, sales channel or transaction status. We do not normally receive the full application, payment or account information you provide directly to a provider.
Awin and the participating provider may process personal information as separate or joint controllers for their own purposes. Their processing is governed by their own privacy information. You can read Awin’s privacy policy at www.awin.com/gb/privacy.
7. Cookies and similar technologies
The website uses cookies and similar storage or access technologies. Some are necessary for the website to function. Others may support preferences, analytics, performance, affiliate attribution or marketing.
We intend to use a third-party consent-management platform to provide the cookie banner and preference controls. Where consent is legally required, non-essential technologies will be used in line with the choices you make through that platform.
The separate Cookie Policy and the consent settings will identify the technologies in use, their providers, purposes and durations. You can normally revisit or change your choices through the cookie-settings link on the website. Blocking some technologies may affect certain features, including affiliate attribution.
8. Who we share personal information with
We may share personal information where reasonably necessary with:
- Awin and other affiliate or attribution partners;
- participating providers and their technology partners when you choose to visit, enquire with or apply through a provider;
- website hosting, cloud, database, email, security, analytics, consent-management, customer-support and IT service providers;
- data and comparison suppliers that help us display products, prices, availability or provider information;
- professional advisers such as accountants, auditors, insurers and legal advisers;
- regulators, courts, law-enforcement bodies, public authorities or other parties where disclosure is required by law or needed to establish, exercise or defend legal rights; and
- a buyer, investor or successor if all or part of our business or assets is sold, transferred, reorganised or merged, subject to appropriate confidentiality and data-protection measures.
Some recipients, including Awin and participating providers, may determine their own purposes and means of processing and therefore act as independent or joint controllers. You should review their privacy notices before giving them personal information.
We do not sell personal information as a standalone product.
9. International transfers
Some of our service providers, affiliate partners or participating providers may process personal information outside the United Kingdom. Data-protection laws in those countries may differ from UK law.
Where a restricted international transfer takes place, we will seek to use a safeguard recognised by applicable UK data-protection law, such as an adequacy regulation, an approved contractual mechanism or another lawful transfer arrangement. You may contact us for further information about safeguards relevant to our own processing.
Awin operates internationally and may transfer information within its group or to service providers in other countries. Please consult Awin’s privacy policy for details of its transfers and safeguards.
10. How long we keep personal information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including any legal, accounting, tax, security or dispute-resolution requirements. We then delete, anonymise or securely dispose of it.
| Information | Typical retention approach |
|---|---|
| Contact enquiries and ordinary correspondence | Usually up to 24 months after the enquiry is resolved, unless a longer period is needed for a complaint, dispute or legal obligation. |
| Accounts and saved comparisons | For the life of the account, then usually up to 24 months after closure or inactivity, subject to security, dispute and legal needs. |
| Consent and marketing records | Until consent is withdrawn or the information is no longer needed. A limited suppression record may be kept so that we respect an opt-out. |
| Technical, security and diagnostic logs | Typically up to 12 months, although a longer period may apply where an incident, fraud concern or legal claim requires it. |
| Affiliate, commission, accounting and tax records | Usually up to seven years where needed for reporting, accounting, tax, audit or dispute purposes. |
| Cookie and tracking information | As specified in the Cookie Policy and consent settings. Awin publishes its own retention information for data it controls. |
These periods are general guidelines. We may retain information for a shorter or longer period where the nature of the information, the purpose, the risk, a legal requirement or an active dispute makes that appropriate.
11. How we protect personal information
We use reasonable technical and organisational measures designed to protect personal information against accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure. These measures may include access controls, authentication, encryption where appropriate, secure hosting, backups, monitoring, software updates and limiting access to people who need the information for a legitimate business purpose.
No website, transmission or storage system can be guaranteed to be completely secure. You are responsible for keeping account credentials confidential and for using a strong, unique password where an account feature is offered.
12. Your data-protection rights
Depending on the circumstances and the lawful basis used, you may have rights to:
- be informed about how your personal information is used;
- request access to personal information held about you;
- ask us to correct inaccurate or incomplete information;
- ask us to erase information in certain circumstances;
- ask us to restrict processing in certain circumstances;
- receive certain information in a portable, machine-readable format and ask for it to be transferred where applicable;
- object to processing based on legitimate interests, including an absolute right to object to direct marketing;
- withdraw consent at any time where processing is based on consent; and
- raise a complaint about our use of personal information.
These rights are not absolute and may not apply in every situation. We may need to ask for information to confirm your identity and clarify your request. We will not normally charge a fee, although the law may allow a reasonable fee or refusal in limited circumstances.
To exercise a right, email info@toucanchoose.com. If your request relates to information controlled by Awin or a participating provider, you may also need to contact that organisation directly.
13. Data-protection complaints
You can raise a complaint about how ToucanChoose has handled your personal information by emailing info@toucanchoose.com with the subject line “Data protection complaint”. Please explain the issue and include enough information for us to investigate it.
We will provide a clear way to make a complaint, acknowledge a data-protection complaint within 30 days, investigate it appropriately and communicate the outcome without undue delay. We may contact you if we need more information.
You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection. We would appreciate the opportunity to address your concern first, but you do not have to contact us before approaching the ICO.
Information Commissioner’s Office: www.ico.org.uk | Telephone: 0303 123 1113
14. Marketing communications
We will only send electronic marketing where we have a lawful basis to do so. Where consent is required, we will ask for it. Any marketing message we send will include a simple way to unsubscribe or opt out.
You can ask us to stop direct marketing at any time by using the unsubscribe option in a message or emailing info@toucanchoose.com. Stopping marketing will not stop service or administrative messages that are necessary for an account, enquiry or transaction-related matter.
15. Automated decisions and profiling
The website may automatically filter, sort or rank offers using the criteria you select, offer data, availability information and commercial or technical rules. Affiliate systems may also attribute a referral or transaction using identifiers and tracking information.
ToucanChoose does not currently use personal information to make solely automated decisions that produce legal effects or similarly significant effects on users. If this changes, we will update this policy and provide the safeguards required by law.
16. Children
The website and the products compared through it are intended for adults who can enter into contracts with third-party providers. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, please contact info@toucanchoose.com so that we can review and, where appropriate, delete it.
17. Third-party websites
Our website contains links to provider websites and other third-party services. We do not control those websites and are not responsible for their privacy practices, security or content. A provider will generally collect and use the information you submit on its website under its own privacy notice. Please read the relevant notice before providing personal information.
18. Changes to this policy
We may update this policy to reflect changes to the website, our partners, technologies, business practices or the law. The updated version will be posted on the website with a revised effective or “last updated” date. Where a change is significant and we have suitable contact information, we may also provide an additional notice.
19. How to contact us
Questions, requests or complaints about this policy or our use of personal information can be sent to:
| Controller | Codique Ltd, trading as ToucanChoose |
|---|---|
| Company number | 10325352 |
| Registered office | 9 Clifton Avenue, Brymbo, Wrexham, LL11 5FS |
| info@toucanchoose.com |