This is the privacy notice of Pozitive Insurance Solutions Limited (company number: 12300506). Our registered office is 7th Floor, Wellington House, 90-92 Butt Road, Colchester, Essex CO3 3DA.
The privacy and security of your personal data is very important to us so we want to assure you that your information will be properly managed and protected by us at all times. Please read this privacy notice carefully as it explains how we may collect and use your personal data.
Pound Insurance is a trading styles of Pozitive Insurance Solutions Ltd and are together referred to as we, us or our in this privacy notice.
This privacy notice sets out how we collect, use and store your personal data. This privacy notice also provides certain information that is legally required and lists your rights in relation to your personal data.
This privacy notice relates to personal data that identifies you as a natural person whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact.
For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller we use (or process) the personal data we hold about you in accordance with this privacy notice.
Information we collect and hold about you and where we obtain this from
We will only ask for information that we need. We collect personal data to be able to provide our products and services to you (for example, arranging your insurance cover or administering a claim on your behalf). Without the information we ask for we wouldn’t be able to provide you with a quotation or administer your insurance policy, and it may affect the outcome of any claim you make.
The personal data that we collect may include the following:
Personal data you provide us with in person, via our website, by telephone and in writing, including by email
- Personal data you provide when you enquire about insurance, or when you purchase a policy, through us, including information about what and/or who you want to insure, such as vehicle details, business activities, your home address and other details
- Personal data you provide when you submit a claim directly to us for processing, or where a claim is submitted to us on your behalf
- General information about you and/or your employees, such as name, address, contact details and dates of birth
- Personal data you provide if you subscribe to any of our mailing or newsletter services
- Your claims and credit history
- Financial details, such as your bank account and card details
- Information about your use of our website such as your IP address, which is a unique number identifying your computer, including personal data gathered using cookies
In addition we may obtain or ask you to provide certain special category personal data (known as special categories of data). This includes certain motoring convictions and any medical condition and this privacy notice specifically sets out how we may process these types of personal data.
We collect your personal data from you as a controller when, for example, we obtain quotations for insurance for you, when we set up your policy for you and when we make changes to your policy for you. This may also involve the collection of data from or about others who are associated with you and your insurance policy such as other persons insured on your policies or your employees or representatives. By giving us information about someone else for the purpose of arranging insurance for them under your policy such as a named driver and/or employee you confirm that you have their permission to do so and that you have shared this privacy notice with them.
By asking us to arrange or administer a contract of insurance for you where this involves passing information to us relating to children, you confirm to us that in doing so you are the responsible guardian of the child or, if not, that you have explicit permission from the child’s guardian to share the information with us.
We also collect information from publicly available sources and third party databases made available to the insurance industry for the purposes of reducing fraud and financial crime as well as any other third party databases where your personal data may be held, provided such third parties have lawful bases on which to share such personal data with us.
How we use your personal data and the lawful basis for processing
The following table applies where we are relying on a lawful basis for processing your personal data, other than the basis of consent.
We may rely on one or more of the following lawful bases when processing your personal data for the following purposes:
|Purpose for which we process your personal data||The lawful basis on which we do this|
|To perform our contractual obligations to you. This would include meeting your requests for insurance services (including obtaining insurance quotations, placing cover for you, processing mid-term adjustments and arranging subsequent renewals) and managing your claims||ContractThe data processing is necessary for any contract you may enter into with us|
|To administer your account, including financial transactions for insurance broking||ContractThe data processing is necessary for any contract you may enter into with us|
|To assist in the prevention and reduction of fraud and other financial crime||Legal obligationThe data processing is necessary for us to comply with the law and the requirements of our regulator|
|To handle your claim against one of our clients||Legitimate interestsThe data processing is necessary to pursue our legitimate interest in fulfilling our contractual obligations with our clients, to protect our clients’ interests and to conclude the claim to your satisfaction|
|In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded||Legitimate interestsThe data processing is necessary to pursue our legitimate interest in the management and operation of our business|
|To let you know about similar products and services that may be of interest to you||Legitimate interestsThe data processing is necessary to pursue our legitimate interest in the management and operation of our business|
Special categories of data and criminal convictions
As referenced earlier in this privacy notice we may also need to collect and process special categories of data, such as information about health, in order to perform our contractual obligations to you. The lawful basis on which we can do this is that the processing is necessary for reasons of substantial public interest relating to insurance. We may also collect information on criminal convictions which we may share with third parties. The lawful basis on which we can do this is that the processing is necessary for reasons of substantial public interest relating to insurance.
Who we pass your personal data to
We may need to pass your personal data to other companies which may include:
- Other companies or brands within our group of companies
- The insurers, intermediaries and third party service providers that we use for the purpose of arranging and administering your insurance policy. This may also include risk management assessors, uninsured loss recovery agencies, premium finance providers, loss adjusters and other third parties involved (directly or indirectly) in the administration of your insurance and its associated benefits
- Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as claims handling, IT systems and administrative services and other activities set out in this privacy notice, as well as support activities such as finance and auditing services
- Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
- Other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid request from the police or other third party organisation in the interest of preventing and detecting crimeFraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud
- Credit reference agencies to check your credit history. This check will be recorded on your credit reference file without affecting your ability to apply for credit or other financial products
- Third parties we use to recover money you may owe us or to whom we may sell your debt
- Another company, if our business or part of it is bought or taken over by that company to make sure your insurance policy can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over
The personal information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the UK and the European Union. In the unlikely event that we transfer your personal information outside the European Union we will ensure that an adequate level of protection is in place to protect your personal information such as putting in place contractual protections which have the purpose of ensuring the security of any information passed and putting in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information.
How we contact you about other products and services
We may from time to time process your personal data to let you know about similar products and services that may be of interest to you, or to keep you up to date on the latest insurance news and/or risk management advice. This is because we value you as a client and are committed providing you with the certainty necessary to help you manage the risks you face. Our lawful basis for processing your personal data in this way is as is necessary to pursue the legitimate interests of our business, unless we have otherwise obtained your consent to do so. We may contact you by post, telephone or e-mail. You will be given the option to stop receiving any communications from us in this regard at any time however please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.
Accessing our website and cookies
When you visit one of our websites we may collect information from you, such as your email address, IP address and other online identifiers. This helps us to track unique visits and monitor patterns of customer website traffic, such as who visits and why they visit. We use third parties to collate IP addresses to help us understand our Internet traffic data and data regarding your browser type and computer. We may also use web usage information to create statistical data regarding the use of our website. We may then use or disclose that statistical data to others for marketing and strategic development purposes, but no individuals will be identified in such statistical data.
Internet browsers normally accept cookies by default, although it’s possible to set a browser to reject cookies. Rejecting cookies may restrict your use of our website and/or delay or affect the way in which our website operates.
The open nature of the internet is such that data may flow over networks without security measures, and may be accessed and used by people other than those for whom the data is intended. While this is outside of our control, we do take the protection of your information very seriously and aim to apply appropriate levels of security at all times.
We accept no responsibility for the privacy policies of any sites visitors can access through our website.
We will only store your data for as long as is necessary to comply with the requirements of your insurance contract(s) and any legal obligations or lawful processing conditions that may exist as a result. You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep your information. If this is the case we will let you know our reasons.
You can ask us to:
- Provide a copy of your personal information
- Correct or delete unnecessary or inaccurate personal information
- Restrict or to object to the use of your personal information at any time
- Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you
- Where we rely on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you don’t want us to contact you again
How to contact us
If you need to contact us in connection with the use or processing of your personal data, or you have any questions or concerns about this privacy notice or your data protection rights, you can get in touch with our data protection co-ordinator as follows: –
Data protection co-ordinator
Pozitive Insurance Solutions Ltd
7th Floor, Wellington House,
90-92 Butt Road,
Essex CO3 3DA
You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement. Further details about the ICO are available at: www.ico.org.uk