TERMS AND CONDITIONS

Push Group Ltd

Last Updated: [Feb 2026]
Version: 2.0

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Advertising, Communications & Artificial Intelligence

1. Acceptance of Terms

By accessing this website, submitting a form, or engaging with our advertisements, you confirm that you have read, understood, and agreed to these Terms and Conditions. If you do not agree, you must not use our website or services.

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2. Advertising Platforms and Lead Collection

We may promote our services using third-party advertising platforms, including but not limited to Google Ads, Microsoft Advertising, Meta platforms (Facebook, Instagram, Messenger, WhatsApp), Outbrain, and Mediago.

When you submit your information through our website or via an advertisement, including lead forms hosted on third-party platforms, your data is collected directly by us and used in accordance with these Terms and our Privacy Policy.

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3. Types of Communications and Contact Methods

We may contact you using various methods depending on the nature of your enquiry and the consent you provide. Communications may include:

3.1 Our Communications

• SMS text messages sent via automated systems to confirm receipt of your enquiry or to follow up asking if you are still interested in the services
• Email correspondence about your enquiry
• These communications are marketing or service-related and do not constitute advice or sales activity

3.2 Partner Communications

When you consent to be contacted, we will share your details with relevant partner companies who will contact you directly using:

• Live telephone calls made by human agents
• Email correspondence
• SMS text messages

Partners will discuss services related to your enquiry and may provide advice, quotes, and sales information.

3.3 Identification and Transparency

• All our SMS messages clearly identify Whichhealthinsurer.co.uk as the sender
• All SMS messages include opt-out instructions (e.g., “Reply STOP to opt out”)
• Partner companies will identify themselves when they contact you
• We do not use fully automated or AI-generated phone calls

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4. Data Sharing with Third-Party Partners

To provide you with comprehensive service and relevant information, we share your contact details with carefully selected third-party partners who can assist with your enquiry.

4.1 Categories of Third-Party Partners

We work with partners in the following categories:

• Financial Services Providers (mortgage brokers, loan providers, financial advisors)
• Insurance Providers (insurance brokers and underwriters)
• Legal Services Providers (solicitors, conveyancers, legal document services)
• Property and Real Estate Services (estate agents, property valuators, surveyors)
• Home Services Providers (trades people, contractors, home improvement specialists)
• Utility and Telecommunications Providers (energy suppliers, broadband providers)

4.2 How Data Sharing Works

When you submit an enquiry:

1. We receive your contact details and enquiry information
2. We send you an automated SMS confirmation via our Twilio service
3. We immediately share your details with one or more relevant partner companies
4. Partners contact you directly to discuss services related to your enquiry
5. We may send follow-up SMS messages asking if you remain interested

4.3 Partner Relationships

• Our Partners are independent data controllers responsible for their own data processing activities. We do not jointly decide on marketing content or timing.
• We receive payment from partners either on a per-lead basis or commission arrangement
• Each partner must comply with UK GDPR and PECR independently
• Partners may have their own terms and privacy policies which apply to their services
• You have the right to manage your preferences with each partner separately

4.4 Partner Accountability

We conduct due diligence on all partners to ensure they maintain appropriate data protection standards and comply with UK marketing regulations. However, once your data is shared with a partner acting as an independent controller, they become directly responsible for their processing activities and communications with you.

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5. Your Consent and Communication Preferences

By submitting your details through our website, advertisements, or enquiry forms and ticking the consent checkbox, you provide explicit consent for the following:

5.1 What You’re Consenting To

When you tick the consent checkbox and submit your enquiry, you consent to:

From Push Group Ltd:

• Receiving automated SMS messages confirming receipt of your enquiry
• Receiving follow-up SMS messages asking if you remain interested
• Your contact details being shared with relevant partner companies

From Our Partner Companies:

• Being contacted via live telephone calls, email, and SMS
• Receiving information, advice, quotes, and offers related to your enquiry
• Partners processing your data as independent controllers

5.2 Purpose of Contact

Contact from us and our partners is for the purpose of:

• Responding to your specific enquiry
• Providing information about requested services
• Offering quotes and advice on related services
• Following up on your service request
• One or more of our carefully selected partners may contact you about services that directly relate to the enquiry submittedrming you about complementary services that may assist you

5.3 What Your Consent Means

Your consent is:

• Freely Given: Providing consent is voluntary
• Specific: You know exactly who will contact you and how
• Informed: We’ve clearly explained the data sharing and contact methods
• Unambiguous: Your consent is given by actively ticking a checkbox

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6. Lawful Basis for Processing (UK GDPR Compliance)

For UK and EEA users, we process personal data under the following lawful bases:

6.1 For Lead Generation and Partner Referral

• Lawful Basis: Consent (as described in Section 5)
• Purpose: Sharing your details with partners, sending SMS communications, enabling partners to contact you
• Legal Requirement: Required under PECR for SMS marketing and third-party data sharing

6.2 For Service Coordination

• Lawful Basis: Legitimate interests (where your rights don’t override our interests)
• Purpose: Managing lead flow, coordinating with partners, maintaining records of referrals
• Balancing Test: We’ve assessed that connecting you with relevant service providers serves both your interests (getting assistance) and our business interests (lead generation)

6.3 For Business Operations and Compliance

• Lawful Basis: Legal obligation and legitimate interests
• Purpose: Maintaining records for tax purposes, complying with regulatory requirements, preventing fraud
• Retention: Required records maintained for up to 6 years for legal compliance

Important: Consent can be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal. Withdrawing consent will stop future communications but will not affect services already in progress with partners.

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7. SMS Marketing Compliance (PECR)

All our SMS communications comply with the Privacy and Electronic Communications Regulations (PECR).

7.1 Our SMS Practices

• Every SMS clearly identifies “Push Group” or “Push Group Ltd” as the sender
• Every SMS includes clear opt-out instructions
• We use Twilio as our SMS service provider
• SMS messages are automated but contain only service-related information

7.2 Types of SMS You’ll Receive

Confirmation Messages:

“Push Group: Thanks for your enquiry about [service]. We’re connecting you with a specialist partner who will contact you shortly. Reply STOP to opt out. Info: pushgroup.co.uk”

Follow-Up Messages:

“Push Group: Are you still interested in [service]? Our partner is ready to help. Reply YES to continue or STOP to opt out.”

7.3 SMS Frequency

• Initial confirmation: 1 message immediately after form submission
• Follow-ups: Typically 1-2 messages if you haven’t responded to partner contact
• Maximum: We will not send more than 3 SMS messages per enquiry

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8. Telephone Preference Service (TPS) and Corporate TPS Compliance

We respect your registration with the Telephone Preference Service (TPS) and Corporate Telephone Preference Service (CTPS).

• Where you have provided specific consent via our forms, this overrides TPS/CTPS registration for contact from us and our partners
• Your consent constitutes permission to be contacted despite TPS/CTPS registration
• You can update your TPS/CTPS preferences at any time at www.tpsonline.org.uk or www.ctpsonline.org.uk
• You can also opt out directly via our opt-out mechanisms (see Section 9)

Note: Your consent to our partners means they may also contact you despite TPS registration, as your consent provides the legal basis for contact.

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9. Your Right to Opt Out and Withdraw Consent

You have complete control over the communications you receive and can withdraw consent at any time.

9.1 How to Opt Out

From Push Group SMS Messages:

• Reply “STOP” to any SMS message from us
• Email info@pushgroup.co.uk with “Unsubscribe” in the subject line
• Your number will be added to our suppression list within 48 hours

From Partner Communications:

• Inform the partner directly during any communication that you wish to opt out
• Use the unsubscribe link in partner emails
• Reply STOP to partner SMS messages
• Contact us at info@pushgroup.co.uk and we will inform relevant partners

General Data Deletion:

• Email info@pushgroup.co.uk to request deletion of your data from our systems
• We will process deletion requests within 30 days
• Note: Partners maintain their own records as independent controllers

9.2 Withdrawal Timeframe

• SMS opt-outs: Processed within 48 hours (excluding weekends and bank holidays)
• Email opt-outs: Processed within 48 hours
• Data deletion requests: Completed within 30 days
• Partner opt-outs: You must contact partners directly or allow us to notify them (up to 7 days)

9.3 Effect of Withdrawal

• Stops all future marketing communications from Push Group
• Prevents us from sharing your details with any new partners
• Does not affect relationships already established with partners (you must opt out with them separately)
• Does not affect any services or contracts already in progress

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10. California Consumer Privacy Rights (CCPA/CPRA)

For California residents, we comply with the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Your Rights:

• Right to Know: What personal information we collect, use, disclose, and share
• Right to Access: Request copies of your personal information
• Right to Delete: Request deletion of your personal information (subject to legal exceptions)
• Right to Opt-Out: Opt out of the sale or sharing of personal information
• Right to Non-Discrimination: Not be discriminated against for exercising your rights
• Right to Correct: Request correction of inaccurate personal information

Important Clarification:

• We Do Not “Sell” Personal Information in the traditional sense
• We share data with partner companies for business purposes (lead generation and referral)
• Partners pay us for leads, but this is structured as a business service, not a data sale
• California residents can opt out of this data sharing by not consenting or by withdrawing consent
• We may request reasonable information to verify your identity before processing rights requests.

To Exercise Your Rights:

• Email: info@pushgroup.co.uk
• Phone: 0203 005 9877
• We will verify your identity and respond within 45 days

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11. Advertising Measurement and Tracking Technologies

We use cookies, pixels, and similar technologies provided by advertising platforms to:

• Measure advertisement performance and conversion rates
• Improve campaign targeting and relevance
• Analyze user behavior on our website
• Prevent fraud and ensure security
• Optimize lead generation effectiveness
• We obtain your consent before placing non-essential cookies via our cookie banner

Your Choices:

• Manage cookie preferences through your browser settings
• Opt out of targeted advertising via industry tools:
  • Your Online Choices: www.youronlinechoices.com
  • Network Advertising Initiative: www.networkadvertising.org/choices
• Adjust privacy settings on advertising platforms (Google, Facebook, etc.)

Required Cookies:
Some cookies are essential for website functionality and do not require consent. These include:

• Security and authentication cookies
• Session management cookies
• Load balancing cookies

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12. Automated Decision-Making and Profiling

12.1 How We Use Automation

We use automated systems for:

• Lead routing: Automatically determining which partner(s) are most relevant for your enquiry based on service type and location
• SMS triggering: Automatically sending confirmation and follow-up SMS messages
• Lead qualification: Basic scoring to assess lead quality
• Scoring does not affect pricing, eligibility or access to services, it only affects which partner is best suited to receive the enquiry.

12.2 Safeguards in Place

• No automated decisions with legal or similarly significant effects are made solely by automated means
• Partner matching is based on objective criteria (service category, geography)
• Human oversight is maintained for quality assurance
• You can contact us to understand how matching decisions are made

12.3 Your Rights

• You can request information about the logic involved in automated processing
• You can challenge automated decisions by contacting info@pushgroup.co.uk
• You have the right to human intervention where decisions significantly affect you

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13. Data Security and Retention

13.1 Security Measures

We implement appropriate technical and organizational measures to protect personal data, including:

• Encryption of data transmission (SSL/TLS)
• Secure storage systems with access controls
• Regular security assessments
• Staff training on data protection and security
• Secure data sharing protocols with partners
• Use of reputable third-party service providers (Twilio for SMS)

13.2 Data Retention Periods

After retention periods expire, data will be securely deleted or anonymized unless we have a legal obligation to retain it longer.

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14. International Data Transfers

Some of our service providers and partners may process data outside the UK.

14.1 Our Service Providers

• Twilio (SMS Service): US-based company with UK data centers; certified under UK-International Data Transfer Agreement (IDTA) UK and the UK Addendum to EU SCC’s
• Advertising Platforms: Google, Meta, Microsoft – may process data in various locations with appropriate safeguards

14.2 Safeguards

Where we transfer data internationally, we ensure:

• Use of service providers with UK adequacy decisions or appropriate safeguards
• Standard Contractual Clauses (SCCs) where required
• Encryption and additional security measures
• Contractual commitments from recipients

You have the right to request information about international transfers and copies of relevant safeguards by contacting info@pushgroup.co.uk

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15. Your Data Protection Rights

Under UK GDPR, you have the following rights:

Response Times:

• We will acknowledge requests within 3 business days
• We will fully respond within 30 days (may extend to 60 days for complex requests)
• All requests are free of charge unless manifestly unfounded or excessive

Right to Complain:
You can lodge a complaint with the Information Commissioner’s Office (ICO):

• Website: www.ico.org.uk
• Phone: 0303 123 1113
• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

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16. Partner Data Sharing Agreements

We maintain written agreements with all partners to ensure:

• Partners understand the consent provided by leads
• Partners commit to GDPR and PECR compliance
• Partners maintain appropriate security measures
• Partners respect opt-out requests
• Clear accountability for data processing activities

Partner Responsibilities:
Each partner is an independent data controller and is responsible for:

• Their own compliance with UK GDPR and PECR
• Providing their own privacy policies and terms
• Handling their own data subject requests
• Maintaining their own opt-out/suppression lists
• Ensuring their staff are trained in data protection

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17. Changes to These Terms

We may update these Terms periodically to reflect:

• Changes in our business practices
• New legal or regulatory requirements
• Improvements to our services
• Changes in technology or service providers

Notification:

• Updated Terms will be posted at pushgroup.co.uk/terms with a “Last Updated” date
• Material changes will be notified via email to recent enquiries (where we have consent)
• Continued use of our services after changes constitutes acceptance

Version History:

• Version 2.0: [DATE] – Updated for GDPR/PECR compliance, SMS disclosure, AI transparency
• Version 1.0: [ORIGINAL DATE] – Initial terms

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18. Governing Law and Jurisdiction

These Terms and Conditions are governed by the laws of England and Wales.

Dispute Resolution:

• Any disputes arising from these Terms shall be subject to the exclusive jurisdiction of the courts of England and Wales
• We will attempt to resolve disputes amicably before resorting to legal proceedings

California Residents:
Nothing in these Terms limits rights provided under California privacy laws for California residents.

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19. Contact Information

For General Enquiries:

Push Group Ltd
Huckletree Liverpool Street
1 Primrose Street
London EC2A 2JN

Email: info@pushgroup.co.uk
Phone: 0203 005 9877
Website: pushgroup.co.uk

Registered Office:

Spaces, The Charter Building
Charter Place, Uxbridge
Middlesex, England
UB8 1JG

Company Registration Number: 06237443

For Data Protection Matters:

Data Protection Contact: info@pushgroup.co.uk

ICO Registration Number: ZA557123

You can verify our ICO registration at: ico.org.uk/ESDWebPages/Entry/ZA557123

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20. Definitions

“We,” “Us,” “Our”: Refers to Push Group Ltd, company number 06237443, ICO registration ZA557123

“You,” “Your”: Refers to the individual submitting an enquiry or accessing our services

“Personal Data”: Information that identifies or could identify a living individual (name, email, phone number, IP address, etc.)

“Processing”: Any operation performed on personal data, including collection, storage, use, disclosure, transfer, or deletion

“Partners” / “Third-Party Partners”: Independent businesses with whom we share lead data, including companies in the categories listed in Section 4.1

“Consent”: Freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to processing of your personal data

“SMS”: Short Message Service text messages sent to mobile phones

“PECR”: Privacy and Electronic Communications Regulations 2003 (as amended)

“UK GDPR”: UK General Data Protection Regulation

“ICO”: Information Commissioner’s Office, the UK’s independent data protection regulator

“TPS”: Telephone Preference Service, the UK’s do-not-call register for individuals

“CTPS”: Corporate Telephone Preference Service, the UK’s do-not-call register for businesses