Updated: 24 August 2020
Unisure Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.unisuregroup.com (Our Site) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Account means an account required to access and/or use certain areas and features of Our Site;
Cookie means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
Cookie Law means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2. Information About Us
Our Site is owned and operated by Unisure Limited, a Limited Company registered in England and Wales under company number 09111373 and regulated by the Financial Conduct Authority with FRN 719400. Unisure Limited is a Unisure Group Company.
Registered address Holland House, 4 Bury Street, London, EC3A 5AW, United Kingdom.
Email address email@example.com
Telephone number +44 203 196 7347
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the Data Protection Legislation (all legislation and regulations in force from time to time regulating the use of personal data and the privacy of electronic communications including, but not limited to, EU Regulation 2016/679 General Data Protection Regulation (GDPR), the Data Protection Act 2018, and any successor legislation or other directly applicable EU regulation relating to data protection and privacy for as long as, and to the extent that, EU law has legal effect in the UK) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
6. What Data Do You Collect and How?
|Type of Data||Purpose of Collection|
|Name and Title|
To allow for the preparation of an accurately priced quotation for insurance as well as the proper administration of applications for insurance and insurance policies, including where appropriate for the administration of claims.
|Date of Birth|
|Details of Occupation and/or Profession|
|Name and Address of Employer|
|Countries Visited as Part of Business Travel|
|Details of Tertiary Education|
|Country of Birth and Nationality Details|
|Basis of Legal Stay in Your Country of Residence|
|Details of Previous Countries of Residence|
|Preferences (such as Alcohol and Tobacco)|
|Interests (such Hazardous Sport or Pastime)|
|Insurance and Financial Information|
|Estate Planning Details|
|Family and Medical History|
|Details of Dependants|
|Details of Beneficiaries|
|IP Address||Website security and integrity|
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Registering you on Our Site and administering Our Site.
- Supplying our products and / or services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and / or services to you and for you.
- Communicating with you. This may include responding to emails or calls from you.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and / or telephone and /or post with information, news, and offers on our products and / or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:
- Quotations for 1 year after the date of quotation, thereafter the data collected will be anonymised; and
- Active policies for 7 years after expiration or cancellation of the policy.
For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy, which is available on request.
9. How and Where Do You Store or Transfer My Personal Data?
We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as binding corporate rules. More information on binding corporate rules is available from the European Commission.
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as third countries and may not have data protection laws that are as strong as those in the UK and/ or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
10. Do You Share My Personal Data?
We may share your personal data with other companies in our group. This includes our holding company and its subsidiaries.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data.
You may also wish to sign up to one or more of the preference services operating in the United Kingdom: The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS), and the Mailing Preference Service (MPS). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a subject access request (SAR).
All subject access requests should be made in writing and sent by email to our Data Protection Officer (David Gardiner – firstname.lastname@example.org).
To make this as easy as possible for you, a Subject Access Request Form is available from our Data Protection Officer, for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is manifestly unfounded or excessive (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request, in not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Our Site comprises public areas and private areas which operate as two distinctly separate and segregated systems, and which perform different functions.
Users who access the public areas of Our Site, which are hosted in WordPress, may receive certain third-party Cookies on their computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on the public areas of Our Site for anonymous statistical analysis and marketing purposes.
These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
Users who access the private areas of Our Site will be required to log in to access these areas. The private areas of Our Site are segregated from, and operate on a completely independent system to, the public areas of Our Site. We do not employ third-party cookies on the private areas of Our Site at present. Our Site may however place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us.
All first-party Cookies used by and on Our Site are used in accordance with current Cookie Law. Because all first-party Cookies used by this site are vital to its functionality, we are not required to obtain specific consent for their use. We use such Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and / or services. We have carefully selected these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please contact our Data Protection Officer.
David Gardiner – email@example.com
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
17. Implementation of this Policy
This Policy shall be deemed effective as of 24 August 2020. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved and authorised by Stephen Paul Conway, Group Chief Executive Officer on 24 August 2020 and is due for review by 24 August 2021.