Privacy Policy

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how FirstPort collects and processes your personal data through your use of this website, including any data you may provide when you sign up to our newsletter, or sign up to a service or product.  

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

Controller

FirstPort is the controller and responsible for your personal data (collectively referred to as “FirstPort”, “we”, “us” or “our” in this privacy policy).  

We have appointed a Data Protection Officer (DPO) and a dedicated Data Privacy team who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please use the contact details set out below.    

Contact details

Full name of legal entity: FirstPort Group Limited  

Email address: dpo@firstport.co.uk  

Emeria Europe SAS may act as a data processor or joint controller depending on processing activities. 

You have the right to raise concerns about the processing of your personal data including your privacy rights. If you remain dissatisfied with our response, you can raise a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority. (www.ico.org.uk).

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated in January 2026.  

It is important that the personal data we hold about you is accurate. Please keep us informed if your personal data changes during your relationship with us.   

Third-party links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.  

The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (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 numbers.  

• Financial Data includes bank account and payment details.  

• Biometric Data includes CCTV if visiting a site. 

• Transaction Data includes details about payments to and from you. 

• 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 website.   

• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.    

• Usage Data includes information about how you use our website and services.   

• Marketing and Communications Data includes communication to and from you, your preferences in receiving marketing from us, our third parties and your communication preferences.  

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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. 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 policy.  

We may process special categories of personal data about you, if you have chosen to provide this to us. This may relate to your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, genetic and biometric data. 

FirstPort does not collect any information about criminal convictions and offences.  . 

If you fail to provide personal data 

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 into with you (for example, to provide you with services).  

How is your personal data collected?

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

• Where we need to perform services to you under a contract.  

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 

• Where we need to comply with a legal obligation. 

• Where you have provided us with consent. You have the right to withdraw consent at any time by contacting us. 

Purposes for which we will use your personal data 

We have set out a description of the ways we plan to use your personal data, and the legal bases we rely on.  

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.  

How we use your personal data

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

• Where we need to perform services to you under a contract. 
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where you have provided us with consent. You have the right to withdraw consent at any time by contacting us. 

Purposes for which we will use your personal data 

We have set out a description of the ways we plan to use your personal data, and the legal bases we rely on. 

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity	Type of data	Lawful basis
To register you as a new customer	(a) Identity(b) Contact	Performance of a contract
To process and deliver services including:  – Manage payments, fees and charges  – Collect and recover money owed to us – Maintenance requests and communication	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract   (b) Legitimate Interest
To manage our relationship with you including:  – Notifying you about changes to our terms – Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract   (b) Legal Obligation  (c) Legitimate Interest (to keep our records updated and to learn how customers use our services)
To enable you to participate in a prize draw, competition or complete a survey	(a) Identity   (b) Contact   (c) Profile   (d) Usage   (e) Marketing and Communications	(a) Performance of a contract   (b) Legitimate Interests (to learn how customers use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity  (b) Contact  (c) Technical	(a) Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)  (b) Legal Obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity   (b) Contact   (c) Profile   (d) Usage   (e) Marketing and Communications   (f) Technical	Legitimate Interest (to study how customers use our services and develop them)
To use data analytics to improve our website services, marketing, customer relationships and experiences	(a) Technical   (b) Usage	Legitimate interest (to define types of customers for our services, to keep our website updated and relevant)
To make suggestions and recommendations about services/products that may be of interest to you	(a) Identity   (b) Contact   (c) Technical   (d) Usage   (e) Profile   (f) Marketing and Communications	Legitimate Interest (to develop our services)

Marketing

We will obtain your consent for marketing and advertising. You have the right to withdraw consent at any time by contacting us.  

Promotional offers from us 

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

You will receive marketing communications if you have requested information from us and you have opted in to receive that marketing.  

Third-party marketing  

We will obtain your consent before we share your personal data with any third party for marketing purposes.   

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the customer portal (My Home) and changing your marketing preferences or by contacting us at any time.   

If you update your contact preferences, we will apply these changes without undue delay and no later than one month from the date of your request. For direct marketing objections, we will stop using your personal data for marketing purposes immediately and add your details to our suppression list to ensure you are not contacted again. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us to provide you with our services.  

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. 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.  

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.   

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.  

Disclosures of your personal data

We may share your personal data with internal and external third parties for the purposes set out in the table above. 

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 policy. We require all third parties to respect the security of your personal data and to treat it in accordance with legislation. 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 instructions. he 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 instructions. 

International transfers

Personal data may be transferred to and processed by our parent company in France. If a transfer takes place, we have in place appropriate safeguards and security measures.

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. We limit access to your personal data to employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.  

We have procedures in place 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. 

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain certain personal data for a twelve year period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

Our legal basis for this period is legislation allows a legal claim to be submitted by a leaseholder within twelve years from the end of the contractual obligation. We therefore retain the data to protect our interests and/or our clients’ interests to enable us to provide evidence in the event of a potential claim. 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, regulatory, tax, accounting or other requirements. 

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. 

In some circumstances we will 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.  

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• 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. 
• Right to withdraw consent. 

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

You will not have to pay a fee to exercise your rights. However, if your request is clearly unfounded, repetitive or excessive we could refuse to comply with your request in these circumstances. 

We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is disclosed to correct individual. 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 calendar month. Occasionally it could 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.

Glossary

Lawful Basis

Legitimate Interest means the interest in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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).

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

Third parties:

Internal third parties

Other companies in the Emeria Group acting as joint controllers or processors who are based either within the UK or inside of the EEA.

External third parties 

• Service providers acting as processors based in the UK or outside of the EEA who provide IT and system administration services. 
• Professional advisers based in the UK who provide consultancy, banking, legal, insurance and accounting services. 
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances. 
• Any data transfer outside of the UK will be governed by standard contractual clauses. 

Your legal rights 

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 legitimate 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 legislation. If we are unable to comply with your request of erasure for specific legal reasons we will notify you of the reason.  

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party). You have the right to object to the processing of 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:  

• If you want us to establish the data’s accuracy. 
• Where our use of the data is unlawful, but you do not want us to erase it. 
• 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.  
• 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.

Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.