We (also referred to as “we”, “us”, or “our”), Insurami Finance LTD, are a company registered In England and Wales with company number 13438299. Registered Office: 82 Rivington Street, Unit 1, London, England, EC2A 3AZ
The purpose of this notice
This Notice is designed to help you understand what kind of information we collect in connection with our products and services and how we will process and use this information. In the course of providing you with products and services we will collect and process information that is commonly known as personal data.
This Notice describes how we collect, use, share, retain and safeguard personal data.
This Notice sets out your individual rights; we explain these later in the Notice but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
What is personal data?
Personal data refers to information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, their gender and contact details.
Personal data may contain information which is known as special categories of personal data. This may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to or sexual orientation.
Personal data may also contain data relating to criminal convictions and offences. For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.
Personal data we collect
In order for us to arrange and administer Deposit Guarantees for you, we will collect and process personal data about you. We will also collect your personal data where you request information about our services, customer events, promotions and campaigns.
We may also need to collect personal data relating to others in order to arrange and administer Deposit Guarantees. In most circumstances, you will provide us with this information. Where you disclose the personal data of others, you must ensure you are entitled to do so.
You may provide us with personal data when completing online quote or contact forms, when you contact us via the telephone, when writing to us directly or where we provide you with paper based forms for completion or we complete a form in conjunction with you.
We will share your personal data within our firm, group of companies, business, and with business partners. This is normal practice within our industry where it is necessary to share information in order to place, quantify and underwrite risks, to assess overall risk exposure and to process claims. It is also necessary to determine the premium payable and to administer our business.
We also share personal data with authorised third parties.
This is necessary where we are required to do so by law, where we need to administer our business, to quote for, source, place and administer your Deposit Guarantee to perform underwriting activities and to process claims.
We may record your communications with us when contacting our customer care, complaints and other customer focused functions.Where we collect data directly from you, we are considered to be the controller of that data i.e. we are the data controller. Where we use third parties to process your data, these parties are known as processors of your personal data. Where there are other parties involved in underwriting or administering your policy they may also process your data in which circumstance we will be a joint data controller of your personal data. A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. A data ‘processor’ means the individual or organisation which processes personal data on behalf of the controller. In our line of business, we will process the following categories of data:
- Personal data such as an individual’s name, address, date of birth, gender, contact details and details of historic claims.
- Special categories of personal data such as health and details on historic claims resulting in injury (physical and physiological).
- Data relating to criminal convictions and offences such as details of driving offences or fraud.
Why do we need your personal data?
We will use your personal data for the performance of our contract with you, to quote for and provide you with products and services, to process claims and renewals, to administer your policy and our business, to respond to any requests from you about services we provide and to process complaints. We will also use your personal data to manage your account, perform statistical analysis on the data we collect, for financial planning and business forecasting purposes. In purchasing our products and services you should understand that you are forming a contract with us.
If you contact us for a quote or request details on the services we provide, we consider ourselves as having a legitimate business interest to provide you with further information about our services.
We may email you from time to time to tell you about our services. You can always unsubscribe from these communications. We will retain your personal data at the end of any contractual agreement for a period of six years in the following cases:
- Where you make a complaint.
- Where you have submitted a claim both for injury and non-injury claims.
- Where you have requested a quote.
- Where you have contacted us for details of our services and products.
In the case of you or law enforcement agencies informing us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data. The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis (profiling) and product development and marketing purposes. Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur. Please email email@example.com if you object to the use of, or you have any questions relating to the use of, your data, the retention of your personal data, automated decision-making services/tools and techniques.
Your rightsIndividuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data. These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
- The right to be informed about the personal data being processed;
- The right of access to your personal data;
- The right to object to the processing of your personal data;
- The right to restrict the processing of your personal data;
- The right to rectification of your personal data;
- The right to erasure of your personal data;
- The right to data portability (to receive an electronic copy of your personal data);
- Rights relating to automated decision making including profiling.
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee. In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health related matters.The flow of data within our sector is complex and we ask you to keep this in mind when exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations to help satisfy your request this may impact on timescales. If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact us at firstname.lastname@example.org
Cross–border transfer of personal information
Insurami Finance LTD transfers Personal Data to, or permits access to Personal Data from, countries outside the European Economic Area (EEA). These countries’ data protection laws do not always offer the same level of protection for Personal Data as offered in the EEA. We will, in all circumstances, safeguard Personal Data as set out in this Privacy Notice. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections as EEA data protection laws. EU data protection laws allow Insurami to freely transfer Personal Data to such countries. If we transfer Personal Data to other countries outside the EEA, we will establish legal grounds justifying such transfer, such as model contractual clauses, individuals’ consent, or other legal grounds permitted by applicable legal requirements. Individuals can request additional information about the specific safeguards applied to the export of their Personal Data.
Protecting your data
Security and privacy are priorities for us at Insurami. We are fully GDPR (General Data Protection Regulation) compliant and implement industry standard security strategies to provide high level of data protection. We take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our firm, group of companies, business, and authorised third parties.
If you are dissatisfied with any aspect of the way in which we process your personal data, please email email@example.com. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office (ICO). The ICO may be contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.