Privacy Notice - First2Protect Limited is committed to protecting your privacy
In this Privacy Notice the terms, 'we', 'us' and 'our' are references to First2Protect Limited (First2Protect), First2Protect is part of the LSL group of companies of which the ultimate parent company is LSL Property Services plc (LSL Group). First2Protect is also an Appointed Representative of PRIMIS Mortgage Network a trading name of First Complete Limited (Our Network).
WHY ARE WE ASKING YOU TO READ THIS DOCUMENT?
This Privacy Notice sets out the basis on which any personal data we collect from you or which you provide to us through our website (www.first2protect.co.uk) (Our Site), or via other methods which you may use to communicate with us, including where you have been referred to us from a third party such as an estate agent, financial consultant or mortgage advisor, will be processed by us (Our Services). In some cases we provide our insurance services under the trading names of the 3rd parties but your data is processed in the same way. Where this is the case the brand names we use are listed below.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it, including:
- What information is being collected if you are a prospective or existing customer?
- In what circumstances will your Special Category Data and Criminal Disclosures be collected?
- The legal basis upon which we deal with your information
- The basis upon which Our Network will deal with your information
- Use of the information we collect
- What is the source of the information we collect?
- Data retention
- Disclosure of information
- Use of automated processing, automated decision making and profiling
- Third party websites
- Your rights
Your privacy is important to us, and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws.
By accessing, browsing or otherwise using Our Site or Our Services you confirm that you have read and agree to this Privacy Notice. If you do not agree with any part of this Privacy Notice, you should not use Our Site or use Our Services.
We reserve the right to change the contents of Our Site, including this Privacy Notice at any time, by posting such changes on Our Site. It is your responsibility to familiarise yourself with the Privacy Notice regularly to ensure that you are aware of any changes. Your continued use of Our Site following the posting of any such changes will constitute your acceptance of the revised Privacy Notice.
We may collect personal information from you in connection with your use of Our Site and Our Services, including such personal information as:
- Your name, email address, telephone number, property address, details of products which you are interested in, proposed renewal dates for any policy and details of your enquiry when you click for a quote or use the ‘contact us’ section of Our Site;
- (when you provide your consent) cookie data which relates to your use of Our Site;
- data sent from your browser to our server which may include:
- the time, date and duration of your visit to Our Site;
- how you access Our Site ( e.g. the referring website address);
- the pages visited on Our Site; and
- your IP address.
We may also collect information from you in connection with the insurance services and/or products provided to you by us, including personal information such as:
- your name, postal address, phone number, email address, date of birth, information about your occupation/employment, credit history, financial dependants, nationality and residency information to allow us to establish your circumstances, needs and preferences in relation to insurance and to provide you with a quote;
- details of the property to be insured, property occupancy information, information about any pre-existing insurance policies including the terms and conditions relating to these and previous claims, details of where in the past you have had insurance refused, cancelled or special terms imposed and information about your insurance requirements in order that we can provide an accurate quote and identify suitable products for you;
- your bank account details, credit or debit card information where we manage financial transactions relating to your insurance policy such as taking payment for services and/or products which we provide and processing refunds;
- any third party associations which you have including details of your mortgage advisor, financial consultant, estate agent, solicitor and/or mortgage provider to allow us to either note their interest on the insurance policy and/or to contact them on your behalf;
- documentation relating to the condition of the property such as a survey or structural report, or previous insurance documentation if these are requested by an insurance provider who is underwriting a policy which you have applied for;
- details provided to us by the underwriter of your policy relating to any claims made by you once your policy is live. This allows us to monitor claims handling processes and ensure we have the information we need to assist you with the renewal of your policy;
- documentation evidencing that we are allowed to communicate with someone else on your behalf, for example a Power of Attorney or Court Order; and
- responses and feedback which you provide to us in customer surveys, in order that we can monitor the quality of the service we provide and make improvements.
In order to provide our service to you there may be circumstances where we need to process personal information from you which is more sensitive. Where we are required to do so we treat this information with the additional protection required under data protection laws. Sensitive personal information we may collect includes summary information of any criminal convictions or offences (charged but not tried yet) (Criminal Disclosures) and/or other sensitive personal information we may ask you to provide. (Special Category Data).
Along with your personal data, we provide this sensitive data to our insurance providers to identify insurance products that meet your needs and to provide you with advice regarding the suitability of any product that we recommend to you. We may also use this information, if needed, where we are able to make reasonable adjustments to our service and communications for you.
If you have children under the age of 16 who reside with you we (and Our Network) will record limited information on our systems about them but this will not include any Special Category Data.
If we process your Special Category Data and any Criminal Disclosures we only do so with your consent however we are also legally obliged to share information on Criminal Disclosures with insurance providers, to enable customers to secure insurance policies, support any claims and to prevent fraud.
Wherever we collect or use your personal data, we will make sure we do this for a valid legal reason. This will be for at least one of the following purposes:
- because it is necessary to fulfil the terms of our contract with you - if you have entered into a contract with us for example to provide insurance advice;
- because it is necessary to support the legitimate interests of our business to provide you with an efficient service that meets your needs - for example, we may need to respond to requests from insurance providers and Our Network relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received. In all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the section on Your Rights below;
- to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities
- where we have obtained a clear consent from you - we will always make it clear when we need your consent and how you can change your permissions at any time thereafter.
If you would like to know more about the legal reasons or legitimate interests that apply to a particular way in which we use personal information you can contact us at any time.
Our Network is authorised and regulated by the Financial Conduct Authority (FCA). Our Network is responsible for the quality of the advice that we provide to you in relation to any insurance products which are regulated by the FCA. In the course of doing so, Our Network will process your information, including your Special Category Data and Criminal Disclosures.
In the course of handling your information and your Special Category Data and/or Criminal Disclosures, Our Network will:
- record and store your information and your Special Category Data and/or Criminal Disclosures on Our Network’s systems run on secure servers. Your information and your Special Category Data/Criminal Disclosures will only be accessed by authorised employees and consultants within, or engaged, by Our Network as necessary for the purposes of supervision, training, quality audits, customer surveys and complaint handling or otherwise to comply with any other legal or regulatory obligation Our Network may have;
- use, and where appropriate transmit, your information and your Special Category Data/Criminal Disclosures to respond to any request from the FCA, the Financial Ombudsman Service, HMRC, the ICO or any other regulatory, law enforcement or governmental body; and
- need to access and process your information and your Special Category Data/Criminal Disclosures to deal with enquiries received from insurance providers that relate to the service we have provided, including the payment of any commission or fees to us that may be linked to the product you have arranged.
Your information and your Special Category Data/Criminal Disclosures will be retained by Our Network either electronically or in paper format for a minimum of six years and possibly for a longer period where this is required to enable Our Network to fulfil its legal and regulatory obligations.
Your information will be used by us in connection with the following purposes:
Providing You with Services:
- to allow us to provide you with the insurance services which you have asked us to provide, including but not limited to offering you insurance advice and and/or putting in place for you the following insurance: buildings and/or contents, home emergency, legal protection, rent protection and/or other property related insurance;
- to keep our client records up to date and ensure we are able to keep in touch with you;
- to improve our services by analysing your personal information so we better understand how you use our services;
- to submit information to insurance product providers both in paper form and online via insurance provider systems in order to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that insurance providers may raise;
- to process financial transactions relating to your insurance policy such as taking payment for services which we provide and providing refunds;
- to provide you with key information relating to your insurance policy and to summarise your insurance cover;
Marketing of Our Services to You:
- to provide you with general updates in relation to the insurance market, in accordance with your preferences;
- to provide you with information which we reasonably believe may be relevant to you based on the services we are providing to you;
Responding to Your queries:
- to help answer any questions which you have asked one of our agents or staff members;
- to provide you with a quote for our services;
Improving Our Site:
- to analyse cookie and website usage data to keep improving our Site;
Legal and Regulatory Obligations:
- to comply with applicable laws where we are obliged to retain and/or disclose certain information;
- to investigate or address claims or complaints relating to your use of our services;
- to upload your information along with full details of the insurance, discussed with you or which you have taken out, to the computer systems of Our Network;
- for internal and external auditing purposes;
- to carry out necessary financial checks;
- to transfer information to any entity which may acquire rights in us; and
- to collect a debt which is owed to us.
The majority of the personal information which we collect will have been voluntarily provided by you, however we may also obtain your personal data from other sources including:
- other LSL Group companies;
- third parties including credit reference agencies and law enforcement/regulatory bodies;
- your mortgage advisor, estate agent, solicitor and/or mortgage provider or any other service provider who offers First2Protect insurance services to you; and
- other publicly available sources.
The personal information that you provide will be retained by us in accordance with applicable laws and our internal Data Retention Policy. However, we will take reasonable steps to destroy or de-identify personal information we hold if it is no longer needed for the purposes set out above. We will only hold your personal information on our systems for as long as is necessary for the relevant purpose for which it was collected. A copy of our Data Retention Policy is available on request.
The information you provide to us will be held on our computers in the UK and will only be accessed by or given to authorised members of staff or of the LSL Group for the purposes set out in this Privacy Notice or for other purposes approved by you. We may also provide your personal information to other companies within the LSL Group for the purposes of administering our business or where services are provided by one LSL Group company to another as outlined in an intra-company services agreement.
We may also disclose your information to the third parties listed below for the following purposes:
- insurers for the purpose of providing us or you with a quotation, to administer your insurance contract and provide services in relation to your insurance contract;
- law enforcement bodies and/or other regulatory entities in order to comply with any legal obligation or court order;
- third parties and their associated companies and sub-contractors who we work with as part of providing our services and performing any administration tasks associated with or incidental to those services, including (but not limited to):
- IT administrators;
- software providers;
- payment service providers for the purpose of processing the payment of your premiums; and
- survey providers in order that we can monitor the quality of the service we provide, obtain feedback and make improvements;
- our professional advisers, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- third parties as necessary in the event of a claim or dispute relating to the use of our services;
- your mortgage advisor, financial consultant, estate agent, solicitor and/or mortgage provider where they referred you to us for insurance services, for the purpose of providing them with progress and/or status updates on the services which we are providing to you and/or to contact them on your behalf;
- Our Network to allow them to monitor the advice which we provide to you; and
- entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation.
These parties may be located in the UK or elsewhere in the world where different privacy laws may apply which may not offer the same level of protection as UK law. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country and that the service provider acts at all times in compliance with applicable privacy laws.
Like many insurance providers, we may use automated processing in order to streamline the services we provide. As part of the processing of your personal data, decisions may be made by automated means. We also use our customers’ data to understand how certain products are performing and to generate business strategy based on statistical analysis. Where we perform profiling of data, where possible this is anonymised to protect your identity. We can do this activity based on our legitimate interests (and they are listed in the use of the information we collect section above) and only where the profiling and other automated decision making does not have a legal or other significant effect on you.
Here are some examples of the types of automated decisions we make:
- underwriting and pricing - the eligibility and pricing of insurance products and services is controlled by insurers, but based on what we know;
- tailoring products and services - we may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them; and
- detecting fraud and financial crime - we have a regulatory obligation to detect, prevent and deter financial crime.
You have rights over automated decisions:
- you can ask that we do not make our decision based on the automated decision alone. We have a non-standard insurance team that have access to a wider range of insurers and products in the event that our standard insurance panel decline providing cover;
- you have the right to:
- request human intervention;
- express your point of view;
- ask for the decision to be explained; and
- challenge the decision,
these rights are not absolute. They do not apply if the decision is:
- necessary for us to enter into or perform a contract with you;
- authorised by law (e.g. for fraud prevention); or
- based on your explicit consent.
- you also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your personal information infringes applicable law.
If you want to know more about these rights, please contact us (contact details are included in the ‘Contact’ section at the bottom of this Privacy Notice).
We use the information you provide us with to keep you informed about products or services which we provide and which we believe you may be interested in. Where we conduct marketing we do so in accordance with applicable laws.
If you have opted-out of receiving our general insurance marketing then we will not send you information relating to this. We may however contact you in future by phone where we reasonably believe (on the basis of services that we are providing to you) that there are additional, different services which you may be interested in. We rely on legitimate interests as a lawful basis for processing your information to conduct the above marketing and we ensure you always have the right to opt-out of receiving marketing communications from us. If you wish to never receive any form of marketing communication from us you can let us know by contacting us (using the details provided below).
We do not pass on your information to other companies for their own marketing purposes but from time to time we may tell you about services offered by other companies within the LSL Group and ask whether you would like to be provided with marketing communications by these companies.
If, at any time, you prefer not to receive further communications from us (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe by means of a link provided in every message that is sent to you by us or by contacting us.
Our Site may contain links to other websites. We accept no responsibility or liability for the content of other websites which are not under our strict control, in particular, we are not responsible for the protection and privacy of any information which you provide whilst visiting other websites and such sites are not governed by our Privacy Notice.
We employ security measures which aim to protect the information provided by you from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is sent to us
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. Click on the links below to learn more about each right you may have:
- To access personal information
- To rectify / erase personal information
- To restrict the processing of your personal information
- To transfer your personal information
- To object to the processing of personal information
- To object to how we use your personal information for direct marketing purposes
- To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
- To lodge a complaint with your local supervisory authority
If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us using the details in the Contact section of this Privacy Notice. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in the following limited circumstances:
- where it is no longer needed for the purposes for which it was collected; or
- where you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see right to object); or
- where it has been processed unlawfully; or
- to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims.
You can ask us to restrict the processing of your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
You can ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
You have a right to lodge a complaint with our local supervisory authority (the contact details for which are set out in the Complaints section of this Privacy Notice) if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
If you have questions or comments about our Privacy Notice or if you wish to exercise your rights mentioned above, please contact our Data Protection Officer by:
Post: Data Protection Officer, Newcastle House, Albany Court, Newcastle Business Park, NE4 7YB; or
Telephone: 0191 233 4600.
If you have any concerns or complaints as to how we have handled your personal data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
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