We take data protection and your privacy very seriously at Claybrooke Life Insurance. Here’s how we handle your information
Last updated: 15/05/2018
This privacy notice aims to give you information on how Claybrooke Life Insurance collects and processes your personal data through your use of this website, including any data you may provide when you submit our online contact form.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
- Who We Are
is the data controller and responsible for your personal data (collectively referred to as “Claybrooke Life Insurance”, “https://www.claybrooke.org.uk”, “we”, “us” or “our” in this privacy notice.
We are a registered data controller with the Information Commissioner’s Office, registration number ZA085780.
Name: Claybrooke Life Insurance
Email address: firstname.lastname@example.org
65 Penarth Road
- The Data We Collect About You
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 and last name.
- Contact Data includes address, email address and telephone number(s).
- Technical Data includes internet protocol (IP) address, 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.
- Product Data includes form responses (the data entered and selected within our online contact form).
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
- How We Collect Your Personal Data
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
- Technical Data from analytics providers such as Google
- How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to effectively perform the service you require
- 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.
Our lawful basis for processing your general personal data:
|Legitimate interests: The processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject||Data used for the purpose of providing the introduction to an FCA authorised broker, in order to provide the service requested by the data subject|
- Sharing of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in our lawful basis for the processing of your general person data:
- FCA authorised Financial Technology (FinTech) companies acting as data processors, joint data controllers or independent data controllers who provide the introduction to FCA authorised brokers by means of IT and system services which may be based on the data you have provided.
- FCA authorised insurance brokers acting as data processors, joint data controllers or independent data controllers in order to provide the services required.
- Your Legal Rights and Your Personal Data
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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.
- 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 your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of the rights set out above, please contact email@example.com for further details.
- Data Security
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.
- Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
- Data Transfers to Third Countries
The data we collect from you may, on occasion, be stored and/or processed at a destination outside the European Economic Area (EEA). It may also be processed by organisations operating outside the EEA who work for us or for one of our suppliers. These organisations may be engaged in the fulfilment of your request, order or reservation, and the provision of support services.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
We use the pieces of information that cookies record to help us improve services for you by, for example:
- enabling a service to recognise your device so you don’t have to give the same information several times during one task
- recognising that you may already have given a username and password so you don’t need to do it for every web page requested
- measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they are fast
- analysing anonymised data to help us understand how people interact with govt services so we can make them better
How to control and delete cookies:
However, if you wish to restrict or block the cookies which are set by our websites, or indeed any other website, you can do this through your browser settings. The ‘Help’ function within your browser should tell you how.
Alternatively, you may wish to visit the AboutCookies.org website which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies.
Please be aware that restricting cookies may impact on the functionality of our website.
If you wish to view your cookie code, just click on a cookie to open it. You’ll see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that gave you the cookie.
For information on how to do this on the browser of your mobile phone, please refer to your handset’s user manual.
Cookies We Use and Why:
Strictly Necessary Cookies
These cookies let you move around the website and use essential features like secure areas. These cookies don’t gather any information about you that could be used for marketing or remembering where you’ve been on the internet.
We use these Strictly Necessary cookies to:
- Remember things like information you’ve entered on forms
- Make sure you connect to the right service on our website when we make any changes to the way the website works.
Cookies we have defined as ‘Strictly Necessary’ cookies will not be used to:
- Gather information that could be used to advertise products or services to you.
- Remember your preferences or username beyond your current visit.
Accepting these cookies is a condition of using the website, so if you prevent these cookies we can’t guarantee our website will perform as expected during your visit.
These cookies help identify information about how you use our website e.g. which pages you visit, and if you experience any errors. These cookies don’t collect any information that could identify you – all the information collected is anonymous and is only used to help us improve how our website works, understand what interests our users, and measure how effective our advertising is.
We use performance cookies to:
- Provide statistics on how our website is used.
- See how effective our adverts are (we don’t use these cookies to target adverts to you when you visit other websites).
- Help us improve the website by measuring any errors that occur.
- Test different designs of our website.
Using our site indicates that you accept the use of ‘Performance’ cookies. Accepting these cookies is a condition of using the website, so if you prevent them we cannot guarantee how our site will perform for you.
Functionality cookies are used to provide services or to remember settings to improve your visit. We use Functionality cookies to:
- Remember settings you’ve applied such as layout, text size, preferences and colours.
- Remember if we’ve already asked you if you want to fill in a survey or review.
- Show you when you’re logged in to the website.
Cookies defined as ‘Functionality’ will not be used to target you with adverts on other websites.
Preventing these cookies may mean we can’t offer you some services and will reduce the support we can offer you. It’s also possible that preventing these cookies will stop us remembering that you didn’t want a specific service.
For example, social media sharing cookies apply when you share our content on a social network such as Facebook or Twitter.
We have relationships with carefully selected and trusted marketing suppliers. Sometimes you might see our adverts on other websites. This is because a cookie has been used to deliver the ad to you. It is important to understand that these cookies are completely anonymous – they are only stored on your computer. No information is ever shared with other websites and you have the ability to opt out of targeted marketing directly from these trusted suppliers.
Preventing these cookies may stop us from offering you some services. All of these cookies are managed by third parties.
- How to Make A Complaint
To exercise all relevant rights, queries or complaints, please contact us at firstname.lastname@example.org to discuss your concerns.
Following this, if you are still dissatisfied, you are able to contact the Information Commissioner’s Office directly at https://ico.org.uk/