Introduction
At insurwave, we take your privacy seriously. insurwave is committed to protecting the privacy of our clients and users of our websites. This Privacy Policy states our policy and practices regarding the collection and use of information on insurwave’s website. When we refer to insurwave, “we”, “us” or “our” we mean our entire company, including our divisions, subsidiaries and affiliates.
We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, via various channels, is only used for the purposes set out in this Policy.
Through this Privacy Policy we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 (“GDPR“) and national laws implementing GDPR.
For the purpose of this Privacy Policy the controller of personal data is insurwave Limited and our contact details are set out in the Contact section at the end of this Privacy Policy. References in this Privacy Policy to our Group of companies refers to insurwave Limited and to other trading divisions, affiliates and subsidiaries of insurwave.
Right to Object: You have a legal right to object at any time to:
(i) use of your personal information for direct marketing purposes; and
(ii) processing of your personal information which is based on our legitimate interests, unless there are compelling legitimate ground for our continued processing.
The information we collect
In general, you can visit the insurwave website without identifying yourself or revealing any personal information.
However, you may choose to provide us with personally identifiable information. Personally identifiable information is information that can be used to identify you, such as your name, email address, telephone number, or similar information.
How we use your personal information
You can be assured that information you provide voluntarily will only be used in connection with your business relationship with insurwave. We will hold, use and disclose your personally identifiable information for our legitimate business purposes including:
- to provide our services to you;
- to maintain our business relationship, where you are a user of our website or a client;
- to deal with your enquiries and complaints;
- to administer our websites;
- to keep our websites and systems secure and prevent fraud;
- where relevant, to meet legal, regulatory or compliance needs;
- to better understand your needs; and
- to provide a better service.
From time to time, we may also use your information to contact you for market research or, with your consent, to provide you with marketing information we think would be of particular interest. At a minimum, we will always give you the choice to opt-out of receiving such direct marketing or market research contact.
We will not use or share the personally identifiable information provided to us online in ways unrelated to the uses described in this statement. More information about how we may share your information can be found at section 5.
The legal basis for processing your personal information
Under GDPR, the main grounds that we rely upon in order to process personal information of uses of our websites and clients are the following:
(a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
(b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;
(c) Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our products and services, keeping you up to date with topical items via newsletters and ensuring that our operations are conducted in an appropriate and efficient manner;
(d) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.
How we share your personal information
We may disclose your personally identifiable information with other parties. Details of those parties are set out below along with the reasons for sharing it.
i. Other Companies within our Group
When you disclose your personal information to us we may share it with other companies in our Group of companies.
We will share your personal information as above for any or all of the following purposes:
- To work with other affiliates and subsidiaries within our Group of companies
- Customer support
- Marketing
- Technical operations
- Account management purposes
As we grow, all of the subsidiaries and affiliates in our Group of companies will enter into the standard contractual clauses approved by the European Commission, to safeguard the personal information which is transferred across our Group of companies to and from the European Economic Area, or have in place other forms of protection approved by the European Commission.
ii. Third Parties
We will share your personal information with trusted third parties where we have retained them to provide services (including marketing and analytic services) or which are required in order to for us to maintain our records.
We require minimum standards of confidentiality and data protection from such third parties. To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place.
iii. Regulatory and Law Enforcement Agencies
We may disclose your personal information if required by applicable law, regulation or as part of a legal process. If we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
iv. New business owners
If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors. If this happens, we will notify users of our websites and clients of such event.
How long we will hold your information
We will retain your personal information for the time necessary to provide the services we perform for you, or stated by the purposes outlined in this Privacy Policy, and you can always request that we stop processing or delete your personal information. The next section sets out more information on your rights.
Your rights on information we hold about you
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
Right of Access
You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
Right of Correction or Completion
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us (see Contact Us section below for details).
Right of Erasure
In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to object to or restrict processing
In certain circumstances, you have the right to object to our processing of your personal information by contacting us (see Contact Us section below for details). For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
Right of Data Portability
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organisation.
The above right exists only in respect of personal information that:
- you have provided to us previously; and
- is processed by us using automated means.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of the above rights by contacting us using any of the methods in the Contact Us section below.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact Us section below.
Use of Cookies
Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The use of cookies is now standard for most websites. We utilise cookies, and other online identification technologies such as web beacons, or pixels to provide users with an improved user experience (together “Cookies”).
You can choose to accept or decline Cookies. Most web browsers automatically accept Cookies, but you can modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. To view more information regarding Cookie settings please visit:
For Microsoft Internet Explorer: http://www.microsoft.com/info/cookies.mspx
For Google Chrome:
http://www.google.com/support/chrome/bin/answer.py?answer=95647
For Mozilla Firefox:
http://support.mozilla.com/en-US/kb/Enabling%20and%20disabling%20cookies
For Apple Safari 5:
http://docs.info.apple.com/article.html?path=Safari/5.0/en/9277.html
CATEGORIES OF COOKIES
Strictly Necessary Cookies: These Cookies are fundamental to website functionality and cannot be switched off without blocking features on the site. They are usually set in response to your actions on the site, such as filling in forms, setting preferences, or logging in.
Performance Cookies: These Cookies allow us (including via the use of third party analytic companies) to gather analytics to improve the performance and functionality of our site. These analytics can include measurements on the popularity of a page, common patterns of how people browse around the site, and how frequently a certain feature is used. We usually aggregate the data for review but in some cases we may collect information on content you have viewed in order to understand what interests you most.
Advertising cookies: insurwave may present ads to you on sites that are not owned or operated by insurwave to promote insurwave services, articles or events. The Cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously re-appearing. These advertisements are solely intended to make you aware of relevant insurwave promotions.
Complaints
If you are unhappy about our use of your personal information, you can contact us using the details in the Contact Us section below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:
Telephone: 0303 123 11113
Website: https://ico.org.uk/concerns/
Post:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
If you live or work outside the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with a different supervisory authority.
Security
We have put in place measures to ensure the security of the information we collect and store about you and will use our reasonable endeavours to protect your personal data from unauthorised disclosure and/or access including through the use of network and database security measures, but these cannot guarantee the security of any data which is collected and stored.
Other websites
Please note that clicking on links and banner advertisements on our websites can result in your browser accessing a third party website, where data privacy practices are different to that of insurwave.
We are not responsible for, and have no control over, information that is submitted or collected by these third parties and you should consult their privacy policies.
Internet based transfers
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Changes to our Privacy Policy
Our Privacy Policy is subject to change from time to time and, if we update it, we will post these changes on this page so that you will be aware of how we use your information.
Contact us
If you have any enquires or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us centrally at privacy@insurwave.com or by post to: insurwave Limited, 42 Southwark St, London, SE1 1UN
Our registered office is at: 6 More London Place, London SE1 2DA