You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Personal data, or personal information, 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, last name, username or similar identifier, title, date of birth, gender and occupation.
- Contact Data includes postal address, email address and telephone numbers.
- Transaction Data includes other details of products and services you have purchased from us directly or via a third party provider we have referred you to.
- 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, purchases or orders made by you, your preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services, including whether you make a claim under a purchased policy or make any changes to your policy.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will periodically review your personal information to ensure that we do not keep it for longer than is necessary.
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your Identity, and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- provide your preferences in order to request quotations for products or services;
- request a call back from a third party provider in relation to a leasing product;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us feedback or contact us.
Third parties or publicly available sources: We may receive personal data about you from various third parties [and public sources] as set out below:
- Technical Data from the following parties:
- analytics providers [such as Google based outside the EU];
- advertising networks [such as [NAME] based [inside OR outside] the EU]; and
- search information providers [such as [NAME] based [inside OR outside] the EU].
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as [NAME] based [inside OR outside] the EU].
- Identity and Contact Data from data providers or aggregators [such as [NAME] based [inside OR outside] the EU].
- Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the EU].
- to enable you to access and use the Services; and/or
- to personalise aspects of our overall service to you, including matching your location and preferences to the relevant leasing products and third party brokers; and/or
- to communicate with you about the Services, your policy or otherwise; and/or
- to process a transaction between you and a third party; and/or
- to use data analytics for the purpose of reporting and to improve our website, products and Services and customer relationship; and/or
- to provide you with information about offers and services which may be of interest or for the purpose of improving our service or that of your insurance provider.
‘Services’ includes the operation of a quotation and referral system for leasing products and the promotion of leasing products and/or policies of third party providers.
We will only use your personal data when the law allows us to and 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.
Legitimate Interest means the interest of our business in conducting and managing our business, including:
- to enable us to give you the best service/products, provide you with quotations from third party providers tailored to your preferences and location and refer you to your chosen broker;
- to enable us to give you the best and most secure experience;
- to study how customers use our products/services, to develop them and grow our business;
- to keep our records updated and to keep our website updated and relevant;
- to inform our marketing strategy;
- for running our business, provision of administration and IT services, network security and to prevent fraud.
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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting 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.
We would like to keep you updated by phone, e-mail or text of other products and services which we feel you may benefit from. For example, we may e-mail you letting you know how you could save money by switching product and services.
You will receive marketing communication from us if you have requested information from us or used our Services and you have not opted out of receiving that marketing. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the use of our Services and/or the purchase of a leasing product.
In order to provide our Services we share your personal data with a panel of third party insurance providers in order to generate the quotes that we provide to you on our website.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party 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 unless and until you take steps to enter into a contract of insurance with them.
You can see a list of our third party providers here
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 your personal data for a longer 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.
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.
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. In addition, we limit access to your personal data to those 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 put in place procedures 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.
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We do not transfer your personal data outside the European Economic Area (EEA).
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 good 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 local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing 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 wish to exercise any of these rights please contact us. We try to respond to all legitimate requests within one 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.