Privacy, Cookies and terms-of-use

Protecting your personal information is extremely important to us at Insurance For Ltd. It’s especially important for a financial administrator like ours, as our customers trust us to look after their personal information.

The way we collect, use, store and share your information is equally important. Our customers expect us to manage their information privately and securely.

This policy tells you how we collect and process your personal information. Please take a few minutes to read it, and show it to anyone else connected to your product or whose data you have shared with us. This policy may be subject to future change.

What does this policy cover?

This privacy policy relates to customers who obtain quotes, purchase our products or enter into agreements with us, and individuals that we cover under employer sponsored schemes.

What is personal information?

When we talk about personal information we mean information about an individual that can identify them, like their name, address, e-mail address, telephone number and other details. It can relate to customers (including prospective customers), their appointed representatives (e.g. powers of attorney), employees, shareholders, business contacts and suppliers. Any reference to “information” or “data” in this policy is a reference to personal information about a living individual.

What information do we hold?

We may collect and process the following personal information about you:

Type of data	Description	Examples of how we use it
Contact	·       Who you are ·       Where you live (including previous addresses) ·       How to contact you ·       Third party contacts (e.g. family members or friends)	·       Servicing your product ·       Marketing ·       Analysis & profiling ·       Enhancing our product and service offering ·       Product underwriting and pricing
Personal Details	·       Age ·       Gender ·       Health details ·       Employment Details	·       Marketing ·       Analysis & profiling ·       Product underwriting and pricing
Transactional	·       Bank and/or card details ·       How you use your product ·       Changes you make to your product or account	·       Servicing your product ·       Making sure our products and services are fit for purpose
Consent & preferences	·       Ways you want us to market to you ·       To obtain information from third parties on your behalf	·       Marketing
Documentary data & national identifiers	·       Details about you that are stored in documents like: ·       Your passport ·       Drivers licence ·       Birth certificate ·       National Insurance number	·       Identification and verification ·       Prevent financial crimes

Where do we get our information from?

• Directly from you – information you provide when you fill in forms.  We may record phone calls for our mutual protection and to improve our customer service standards.
• Information we collect about you or receive from other sources. This could be information you provide to us electronically (through our website or an online portal, for example).

 

• How do we use your information?

We use personal information that we hold about you:

• To carry out our responsibilities resulting from any agreements you’ve entered into with us (e.g. to, underwrite and administer your product, including processing claims) and to provide you with the information, products and services that you’ve asked from us (e.g. quotes and policies).
• To provide you with marketing information about services and products we offer across the Insurance for Ltd group which may be of interest to you.  We will not sell your data to third parties for them to market to you.
• To tell you about changes to our services and products.
• To comply with any applicable legal or regulatory requirements (including “know your customer” checks, or to comply with any applicable regulatory reporting or disclosure requirements).
• For carrying out market research, statistical analysis and customer profiling to help us to improve our processes, products and services and generate new business (e.g. to understand digital behaviours, identify financial attitudes and develop more engaging communications).
• To define our actuarial, pricing and underwriting strategies.
• To run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit.
• For any other purpose that we’ve agreed with you from time to time.

When you apply for a product or to receive a service from us, the application form you fill out or the resulting contract may contain additional conditions relating to the way we use and process your personal information. These will apply in addition to the uses described in this document.

In some cases, we may use software or systems to make automated decisions (including profiling) based on the personal information we have, or collect from others. These may include:

• • The prevention and detection of fraud and financial crime
    To perform transaction monitoring, identity verification, money laundering and sanctions checks, and to identify politically exposed individuals. We may be required by law to perform these activities which may be achieved using solely automated means to make decisions about you. We may use these activities to decline the services you have requested or to stop providing existing services to you.
  • Providing quotes, calculating premiums and underwriting decisions
    We may assess a number of factors including information about you such as your location occupation and hazardous pursuits that you perform. These factors will be assessed against our pricing and underwriting criteria which may include statistics regarding life expectancy, illness, injury and demographic risks.
  • For insurance the factors may include your claims history, where you live. We may use these activities to determine the price of your product and whether we should undertake the risk of insuring you – including how much insurance should be granted to you, how much you should pay for it and whether or not to insure you in the first place.

Using your information in accordance with data protection laws

Data protection laws require us to meet certain conditions before we’re allowed to use your personal information in the way we describe in this privacy policy. We take these responsibilities extremely seriously. To use your personal information, we’ll rely on the following conditions, depending on the activities we’re carrying out:

• • • Providing our contracts & services to you:We’ll process your personal information to carry out our responsibilities resulting from any agreements you’ve entered into with us and to provide you with the information, products and services you’ve asked from us, which may include online services.
    • Complying with applicable laws: We may process your personal information to comply with any legal obligation we’re subject to.
    • Legitimate interests:To use your personal data for any other purpose described in this privacy policy, we’ll rely on a condition known as “legitimate interests”. It’s in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively.  We may use your information to:
      • Carry out market research and product development, which can include creating customer demographics and/or profiling.
      • Develop and test the effectiveness of marketing activities.
      • Develop, test and manage our brands, products and services.
      • Study and also manage how our customers use products and services from us and our business partners, including customer surveys.
      • Manage risk for us and our customers.

      This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.

      The outcome of this assessment will determine whether we can use your personal data in the ways described in this privacy policy (except in relation to marketing, where we’ll always rely on your consent). We’ll always act reasonably and give full and proper consideration to your interests in carrying out this assessment.

      • • • Consent: We may provide you with marketing information about our services or products where you’ve provided your consent for us to do so.
            You may opt-out of marketing at any time by e-mailing us. Alternatively, you can also use the  section of our website.

      Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.

      How long do we keep your information for?

      We’ll keep your personal information in accordance with our internal retention policies. We’ll determine the length of time we keep it for based on the minimum retention periods required by law or regulation. We’ll only keep your personal information after this period if there’s a legitimate and provable business reason to do so.

      For certain research and statistical activities, we may indefinitely retain minimised personal information about you, including medical information, to solely to define our actuarial, underwriting and pricing risk strategies. These activities will not be used to make a decision, or take measures, against you.

      Who do we share your personal information with?

      We’ll only disclose your information to:

      • • • Other companies within the Insurance For Ltd group, insurers, reinsurers and claims assistance companies
          • Our insurer’s regulators, government agencies, law enforcement agencies, fraud prevention agencies, reassurers.
          • Additionally, we may disclose your personal information to third parties:
          • In the event that we sell or buy any business or assets, in which case we’ll disclose your personal data to the prospective seller or buyer of such business or assets.
          • If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
          • For employer-sponsored schemes, we may share some details of your plan with your employer and any professional advisor(s) they appoint on their or your behalf to service the scheme.
          • In order to enforce or apply the terms of any contract with you.
          • If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
          • To protect you and Insurance For Ltd from financial crime, Insurance For Ltd may be required to verify the identity of new and sometimes existing customers. This may be achieved by using various agencies or organisations to search sources of information relating to you (an identity search). If this fails, Insurance For Ltd may need to approach you to obtain documentary evidence of identity.
          • If you make a claim, we may share your information (where necessary) with other insurance companies to prevent fraudulent claims.

      Additionally, your information, including special category and criminal conviction data, may be disclosed to our reassurer and to any other insurance company to whom you apply for products or services.

      The personal information Insurance For Ltd collects from you may be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity.

      If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We may also share information about you with other organisations and public bodies, including the police and we may check and/or file your details with fraud prevention agencies and databases.

      If fraud is detected, you could be refused certain services, finance or employment. Insurance For Ltd and other organisations may also access and use this information to prevent fraud and money laundering.

      Protecting your data outside the UK

      The data that we collect from you may be transferred to, and stored at, a destination outside the UK to third-party suppliers, delegates or agents. We’ll take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this privacy policy, to ensure your personal information is handled with the same protections that we apply ourselves.

      We’ll only transfer your data to a recipient outside the UK where we’re permitted to do so by law (for instance, (A) where the transfer is based on standard data protection clauses adopted or approved by the UK’s Information Commissioner’s Office, (B) where the transfer is to a territory that is deemed ‘adequate’ by the UK, or (C) where the recipient is subject to an approved certification mechanism and the personal information is subject to appropriate safeguards, etc.).

      Unfortunately, sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.

      Your rights

      You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner’s website. If you wish to exercise any of these rights, please get in touch with your customer services team. Alternatively, you can also use the Contact Us section of our website.

      Your rights
      1.	The right to access the personal data that we hold about you.
      2.	The right to make us correct any inaccurate personal data we hold about you.
      3.	The right to make us erase any personal data we hold about you. This right will only apply where for example: ·       We no longer need to use the personal data to achieve the purpose we collected it for ·       You withdraw your consent if we’re using your personal data based on that consent ·       Where you object to the way we use your data, and there is no overriding legitimate interest.
      4.	The right to restrict our processing of the personal data we hold about you. This right will only apply where for example: ·       You dispute the accuracy of the personal data we hold ·       You would like your data erased, but we require to hold it in order to stop its processing ·       You have the right to require us to erase the personal data but would prefer that our processing is restricted instead ·       Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.
      5.	The right to object to our processing of personal data we hold about you (including for the purposes of sending marketing materials to you).
      6.	The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.
      7.	The right to withdraw your consent, where we’re relying on it to use your personal data (for example, to provide you with marketing information about our services or products).
      8.	For automated decisions (including profiling), you have right to: ·       Obtain an explanation of the decision and challenge it ·       Request for the decision to be reviewed by a human being.

      Contacts and complaints

      If you have any questions about this privacy policy or wish to exercise any of your rights, including changing your marketing preferences, please get in touch with Insurance for Ltd
      Alternatively, you can also use the Contact Us section of our website.

      If you have any concerns about the way we process your personal data, or are not happy with the way we’ve handled a request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner’s Office. Their address is:

      First Contact Team
      Information Commissioner’s Office
      Wycliffe House
      Water Lane
      Wilmslow
      SK9 5AF