We collect and process different kinds of personal information about individuals including: the directors/members of our clients or prospective clients, clients who may be sole traders or partners of a partnership; and our clients or prospective client’s employees, customers and suppliers, which we have grouped together as follows: • Identity Data – including name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data – including telephone number (office and mobile), home and business address and email addresses.
• Financial Data – including bank account data, financial records, debt information and credit card information.
• Technical Data – including 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 – including any usernames and passwords which you create for your service accounts, any preferences you express to us and any feedback you provide to us.
• Usage Data – including information about how you use our website and our products.
• Marketing and Communications Data – including your preferences in receiving marketing from us and our third parties and your communication preferences. We do not usually collect any Special Categories of personal information, such as information about your health, political beliefs or sexual orientation. We will notify you at the point of collection if we do need any Special Categories of personal information. Criminal Convictions/Records We may only process information relating to criminal convictions or criminal records where the law allows us to do so. This will usually be where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent or where the information is publicly available. However, as part of our identity checks process we do carry out searches with agencies such as CreditSafe and/or Experian to establish identity and to detect fraud. Such searches may reveal some publicly available information about criminal records or convictions. If you do not provide the personal information we request Where we need to collect personal information by law or under the terms of a contract we have with you and you fail to provide that personal information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to identify a suitable insurance product for you). In this case, we may have to cancel our relationship with you and it may impact on any contracts of insurance that you were looking to purchase.
We collect information about you in a number of ways including through:
• Direct Interactions – You may provide us with Identity, Contact, Financial, Marketing and Communications Data through any applications you make to us or through communications with us; whether by post, phone, email or otherwise. This includes: product applications, creating accounts, filling in contact us forms, providing feedback, telephone queries or completing surveys. It also includes ID documents including passports, driving licences and utility bills you provide to us.
• 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 information by using server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies or by interacting with us through third party platforms such as Twitter, Facebook LinkedIn and You Tube.
Under data protection laws we can only use your personal information if we have a proper legal basis for doing so. Most commonly we will use your personal information in the following circumstances:
• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests (or those of a third party); or
• where you have given consent. Where we are relying on consent as the legal basis for processing your personal information you have the right to withdraw consent at any time by contacting us at email@example.com A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own fundamental rights and interests. Purposes for which we will use your personal information We may use the personal information held about you for various purposes and which of the legal bases we rely on to do so are set out in the following table:
Our site is made available free of charge.
We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.
If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes please contact the Marketing Department at First Floor, Equinox North, Great Park Road, Bradley Stoke, Bristol, BS32 4QL.
We may disclose your information to the following third parties:
• Insurers, reinsurers and other insurance intermediaries in order to provide you with insurance broking and related services
• Lenders who are to be protected by any policy you purchase using our services;
• The FCA in accordance with our regulatory and reporting requirements;
• Credit reference or fraud prevention agencies within the EEA to:
– undertake a search in order to verify your identity (and a record of this search will be retained);
– check the details and information you have supplied to us against any database, public or otherwise;
– assist other companies with verification and identification;
– to identify and prevent fraud, money laundering and other criminal activity;
– to protect our business; and
– to comply with laws.
• Law enforcement agencies within the EEA to the extent we are required to do so by law.
• Third party service providers including IT service providers based both inside and outside the EEA.
• Our bankers in order to comply with their regulatory and legal obligations and to provide services to us.
• Professional advisors including lawyers, accountants, loss adjusters, debt collection agencies and consultants so that they can provide services to us and/or advise us accurately in relation to any agreement we may have with a client.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, to establish or defend any legal claims or to enforce any terms of any contracts entered into between you and us. This includes exchanging information with other companies and organisations, including credit reference agencies and fraud prevention agencies, for the purposes of fraud protection and credit risk reduction. If at any time you give us or procure the giving of false of inaccurate information and we suspect fraud we will record this and disclose the relevant details to fraud prevention agencies.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
• Where you have confirmed to us that you are happy for us to do so.
We may transfer your personal information abroad to other countries outside of the UK. If we so do, we will ensure that a similar degree of protection is afforded to your information by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US. We may transfer your personal information abroad to other countries outside of the UK. If we so do we will ensure that the country to which your information is transferred, ensures an adequate level of protection which is at least as good as those in the UK.
Your duty to inform us of changes It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. Your rights in connection with personal information Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org No fee usually required You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. Right to withdraw consent In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact email@example.com Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
We have put in place measures to protect the security of your information. Details of these measures are available upon request. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any regulatory, legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention schedule which is available from firstname.lastname@example.org To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer we will retain and securely destroy your personal information in accordance with our data retention policy.