PRIVACY POLICY VERSION 1.0

Last update: 10 July 2018

POLICY STATEMENT

ifaPROSURE takes data privacy very seriously and recognises the importance of protecting and respecting your personal data. This Privacy Policy describes the information we collect, how we use that information, to whom we pass the information, your rights and key contact information.

  1. Overview

 

To provide you with our insurance brokerage services we need to collect information about you. Our aim is not to be intrusive, and we won’t ask you unnecessary questions. Any information we receive about you will be subject to strict controls to minimise the risk of misuse, including unauthorised access to, or disclosure of, your personal data.

Please read this notice carefully, together with our Terms and Conditions and any other documents referred to in it. Here we set out the basis on which any information we collect about you or from you, or that you provide to us, will be processed by us and other parties in providing you with our services [“ifaPROSURE Services”]. ifaPROSURE (“our”, “us”and “we”) commits to using your information only in accordance with the terms of this Privacy Policy.

For the purposesof this Privacy Policy, the term “information”means any confidential and/or personal data or other information related to users of ifaPROSURE Services, including, but not limited to, corporate and individual customers and their connected parties.

By visiting this website, our partners’ websites, or providing your personal information to one of our employees, for example by telephone or email, you accept and expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

This includes consenting to the processing of any sensitive personal information you provide, as described below in Section 2. It also includes information you provide when you browse our website, request a quote, order insurance with us and when you contact us for other reasons.

If you have concerns about any of the terms of this Privacy Policy, please call us so that we can provide further information.

A special note about children

Children are not eligible to use ifaPROSURE Services. We respectfully ask that minors (persons under the age of 18) do not submit any information to us or use ifaPROSURE Services.

  1. What information we collect

 

Information we may collect from you

We may collect and process the following information about you:

Information you provide to us

You may provide us with information by writing to us, sending us emails, browsing our website or speaking with us on the telephone.

Initial information

To register with ifaPROSURE or use ifaPROSURE Services you must provide your name and work and/or personal email address, company name, job title, work and mobile telephone numbers.

We will ask you to provide details of any claims, losses or circumstances which may give rise to claims or losses, which may include the name and job titles of the individuals working for your company that were involved in those claims or losses.  If you have a third-party compliance consultant we may ask for their contact details.

You may provide the information above via email, in writing or when we speak to you by phone.

In order to pay for ifaPROSURE Services and your insurance policy, you may be asked to provide your bank account and sort code.

When we communicate

When you communicate with us for customer service or other purposes, including by phone, email or using other methods, we retain that information and our responses to you.

Information we collect when you use our website

While you are using our site, we will collect information about you only if you submit a query via our contact form where we ask you to submit your name, email address and a message.

Individuals who are not registered users of ifaPROSURE Services

3rdParties

If it is necessary for you to provide personal information about other individuals in the course of dealing with us, for example regarding directors and employees of a company, or an individual making a claim or potential claim against your company, you should advise them that you will do this.  This information will include: for employees and directors: their name, job title, contact details and details of any claims or potential claims against insurance in which they are or have been involved; for claimants: their name, address, date of birth, contact details, claim details, pension/investment details, and other information that may be included in correspondence between you and the claimant.

Privacy policy notification to 3rdparties

Although the information on third parties is stored for a certain period of time in compliance with applicable law, we will not use it to market to the non-registered person.

Additionally, these persons have the same rights to access and correct information about themselves as registered users of ifaPROSURE Services. You should bring this Privacy Policy to their attention at the earliest opportunity so they aware of how their information will be processed by us and aware of their rights in relation to that information.

Information about you from other sources

We may occasionally receive your contact details from 3rdparties, either as a referral or by purchasing a marketing list, however we will only contact you if you have given permission to the 3rdparty for us to contact you about ifaPROSURE Services.  The information we receive may include your name, company name, work telephone number, mobile number and work email address.

Sensitive data

Data privacy regulations prohibit the processing of ‘special categories of personal data’, also called ‘sensitive data’, unless you havegiven your consent.

Sensitive data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life or sexual orientation. There are also restrictions on processing of criminal convictions and offences.

To avoid infringing these restrictions, it is ifaPROSURE’s policy that we do not ask for, and request that you do not reveal, any sensitive data about yourself or others in any communication with us.

If you do reveal sensitive data, for example in an email, you will be giving express consent for us to process that information by storing the email or other communication.

  1. How we use your information

 

Our primary purpose in collecting your information is to provide you with a safe, smooth, efficient and customised experience. By providing your information to ifaPROSURE and using ifaPROSURE Services you agree that we may use your information for the following purposes:

Fulfilling your requests

We will use your information for the purposes of understanding the insurance requirements of the organisation for which you work, finding the right insurer and underwriter for your policy, and setting up the policy, including dealing with any queries from yourself and the insurer/underwriter.

Managing claims or potential claims

We will use the information you provide to manage claims or potential claims against you.  This includes information you have provided about yourself, people who work at your company, and individuals who make a claim or potential claim against your company.

Communication and customer service

We communicate with our clients on a regular basis via email, phone and/or SMS to provide requested services. These activities include:

  • confirming your order for ifaPROSURE Services;
  • handling claims under insurance contracts that our clients have with us;
  • responding to requests for customer service;
  • resolving customer complaints;
  • issuing invoices and carrying out collection activities; and
  • resolving disputes about billing or transactions.

 

We will also use your email and postal address to:

  • send you information about important changes to our products and services, including notice of any times that our services may not be available; and
  • send notices and other disclosures required by law.

 

Users cannot opt out of these communications, but they will be primarily service-oriented rather than promotional. If you do not wish to receive them in a particular way, please contact us to advise us of your preferred communication method.

Marketing

We also use your email address to send you other types of communications that you can control, including to:

  • provide you with information about services we offer that are similar to those that you have already enquired about or purchased;
  • provide news and updates about the services we offer, and promotional offers based on your activities when using ifaPROSURE Services;
  • make suggestions and recommendations to you about services that may interest you, which may be based on your activity on our website;
  • keep you informed about IFA insurance news; and
  • tell you about new products and features we are developing that you may find useful.

 

You can choose whether to receive some, all or none of these communications, and the methods by which you receive them, when you enquire or complete the registration process (or at any time thereafter) by emailing us, or by calling us and amending your preferences over the phone.

Service improvements

We will use your information to deliver and improve ifaPROSURE Services including:

  • improving our existing, and developing new, products, services, websites, apps and capabilities;
  • for internal business administration and operations purposes, including storage, backup, archiving, troubleshooting, data analysis, testing, research and statistical purposes;
  • detecting, preventing or remediating violations of our policies, Terms and Conditions or other agreements; and
  • as part of our efforts to keep our systems safe and secure, including managing and protecting our information technology infrastructure.
  1. Cookies

 

What is a cookie?

A cookie is a simple text file that is stored on your computer or mobile device by a website’s server; only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier, the site name, and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket.

What to do if you don’t want cookies to be set

Some people find the idea of a website storing information on their computer or mobile device a bit intrusive, particularly if this information is stored and used by a third party without them knowing. Although this is generally quite harmless, you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set; but you need to be aware that you might lose some functions of that website.

How can I control cookies?

If you don’t want to receive cookies, you can change your browser settings so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.

If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.

Please note that if you disable the use of Cookies on this website some functionality such as navigation may not work as intended.

For information about controlling cookies on the browser of a mobile device please refer to your device manual.

Cookies on our website

Our website uses only two cookies as described below.  Both store information on your device only and neither passes information to us or 3rdparties.

NamePurposeExpiry
PHPSESSIDPresents messages when you interact with the contact form.When you close the browser
catAccCookiesSet by the Cookie pop-up to record that you accept the fact that the site uses cookies.30 days

 

  1. Sharing information with third parties

 

To support our business and provide services to you

ifaPROSURE works with third-party service providers who provide important functions that allow us to deliver ifaPROSURE services safely and securely.

By accepting this Privacy Policy and ordering services from ifaPROSURE, you expressly consent to the transfer of your data to those third parties for the purposes listed.

Insurers and underwriters

When we provide ifaPROSURE Services to negotiate your insurance cover, we will provide the name, email address and telephone numbers of client or prospective client contacts to insurers, underwriters and their appointed representatives.  We will also provide any relevant information that you have provided to us about individuals covered by the policy.

When we provide ifaPROSURE Services to assist with handling any claims or potential claims under the insurance, we will pass the claimant’s details, the details of the claim, and information about the individual(s) covered by the policy to the insurers and their appointed representatives and/or lawyers to help manage your claim.

Premium credit providers

We work with premium credit providers to allow you to spread your premium over the policy period.  If you wish to take advantage of this service, we will collect your bank details, a direct debit authorisation, the name of the client contact and their email address, telephone number and work address and pass these details to the premium credit provider.  We will do this only if you request this service and provide us consent at that time.

Compliance support

Our compliance support partner carries out regular review of client files to ensure we are compliant with FCA regulations. We share client files with our compliance support partner for this purpose.

Where required by law and legal process

We may disclose necessary information to the police and other law enforcement agencies, regulatory authorities, self-regulatory authorities or organisations, and other third parties where we are legally compelled and/or permitted to do so.

We may also disclose necessary information in response a civil or criminal legal process.

Mergers and acquisitions

As with any business, it is possible that in the future ifaPROSURE could buy, merge with, or be acquired by, another company. We may disclose your information to the prospective seller or buyer of such business or assets, along with its professional advisers. If ifaPROSURE or a substantial proportion of its assets are acquired by a third party, information held by us about our clients and their connected parties will be one of the transferred assets, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.

Affiliates

If you are referred to us by a third party we may notify them when you book a transaction.

We have a select group of affiliates to whom we occasionally refer customers. If we think you may benefit from these services, we will ask you if you would like us to pass on your details. We will always name the affiliate and the service they provide and ask you for permission before we refer you, and we will pass on your details only where you give us permission to do so. If you consent to the referral, we will typically pass on your name, email address and telephone number.

Third party websites

Our site may, from time to time, contain links to the websites of our business partners, advertisers and affiliates.

Please note that these websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any information to third party websites.

  1. Transferring data overseas

 

All data processing in respect of ifaPROSURE services takes place within the UK.

  1. Data Retention Policy

 

In normal circumstances, we retain information about policies, including premiums paid and the information you provide in setting up the policy, for three years after the date you cease to be a client.  If a claim is made, we will retain claims data for 6 years after the date the claim is settled.   If you notify us of a circumstance that may lead to a future claim, we will retain all information relating to the policy for 40 years, as some claims, for example relating to pensions, may not materialise for many years. In some circumstances, such as an enquiry from a law enforcement agency, we may have to hold information for longer. We may also retain information if required to protect our interests, for example in case of litigation. When data falls outside those retention periods we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.

  1. Systems Security Policy

 

ifaPROSURE has implemented security measures designed to prevent data loss, to preserve data integrity, and to control access to the data.  Only authorised employees of ifaPROSURE and our business partners processing data on our behalf have access to your personal data. All ifaPROSURE employees who have access to your personal data are required to comply with our privacy policy. All business partners are requested by ifaPROSURE to ensure that any of their employees who have access to your personal data have signed non-disclosure agreements. Contracts with business partners acting as data processors for ifaPROSURE involving personal data require an adequate level of security and require that personal data is processed only as instructed by ifaPROSURE.

System security and monitoring

We have put in place suitable technical and organisational measures to protect your data.  Our systems are kept up-to-date with the latest security patches. We operate secure firewalls and anti-virus software.  Our website is protected with Secure Sockets Layer technology to protect the data you send us. Our file hosting partner encrypts the data it holds and is regularly penetration tested for added security.  All incoming files are scanned for viruses and other threats.  Our laptops and other computers are protected by passwords and face-recognition technology to control access.

  1. Customer rights

 

You have the following rights:

To ask us to correct any information we hold about you if it is incorrect.

Whilst we endeavour at all times to keep your information accurate, we welcome your corrections. You can correct your information at any time by contacting us by email or telephone.

To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’.

Our Data Retention Policy (see Section 7) explains the circumstances when we can or are obliged to retain information, however outside of those periods we will delete your information in line with our data retention policy and on request. We will maintain a record that you made an erasure request to reduce the likelihood of us contacting you in the future, but we will use that information for no other purpose.

To ask us to return to you information you provided to us, also known as ‘data portability’.

You can ask us to send you in electronic format the information you provided to us under our Terms   and Conditions or under consent.

To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest.

If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.

You cannot object to processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party. If you previously gave consent and we processed your data on the basis of that consent, you cannot object to that past processing, however you can ask us to stop processing it in the future.

To ask not to be subjected to automated decision making and profiling.

ifaPROSURE puts the human factor at the heart of our customer service, so there are no circumstances when profiling or other automated decision-making will have a legal impact on you.  If you feel you may have been unfairly impacted by profiling, our team can manually assess whether the decision is fair and discuss the situation with you.

To ask for a copy of the information we hold about you.

We will endeavour to respond to your request within 30 days, however at time of high demand we may need 90 days to compile a full response.

To ask us not to process your information for marketing purposes.

You can do this by checking or unchecking certain boxes on the forms we use to collect your information, or by sending us an email or calling us by phone, or by clicking on the ‘unsubscribe’ link(s) at the foot of every marketing or promotional email.

You may exercise any of the above rights by contacting us at info@ifaprosure.com or by calling us.

  1. Contacting us

 

The Data Controller

The Data Controller is ifaPROSURE Limited, Registered Office 57a Broadway, Leigh-on-Sea, Essex SS9 1PE, England, Company Number 06969672.

Contacting us with questions or requests

If you want to exercise your right to access your information or have any questions about this Privacy Policy, ifaPROSURE’s information practices, or your dealings with ifaPROSURE, you can contact us by emailing us at info@ifaprosure.com or by writing to us at the address above.

Complaints to us

If you believe that we have breached a privacy law with which we should comply, please send an email to info@ifaprosure.com. We aim to respond in a reasonable time, normally within 30 days. Our director will look after your complaint and will give you additional information about how it will be managed.

Complaints to the UK Information Commissioner

You have the right to complain to the UK Information Commissioner’s Office if you believe we have not handled your request in an appropriate manner. For information on contacting the Information Commissioner, please see their website.

  1. Changes to this Privacy Policy

 

We may amend this Privacy Policy at any time, as new features are added to ifaPROSURE Services or as we incorporate suggestions from our customers. Any changes we may make will be posted on the ifaPROSURE website, so please check back frequently.

Your continued use of our website and ifaPROSURE Services after a posting of a new version of this Policy will constitute your acceptance of, and agreement to, any changes. If you disagree with the terms of this Privacy Policy, please contact us to discuss your concerns.