If you provide us with somebody else’s personal data, you must provide them with a copy of this privacy notice before doing so.
In order to provide our services, Insure My Villa will collect and use data about individuals. Therefore, Insure My Villa is the controller of your data and this means that we are responsible for complying with data protection laws. Insure My Villa is a trading name of Insure My Villa Limited, which is an appointed representative of Vasek Insurance Services Limited. Vasek Insurance Services Limited is authorised and regulated by the Financial Conduct Authority. Firm Reference Number: 309354. Registered Office: The Walbrook Building, 25 Walbrook, London EC4N 8AW. Registered in England & Wales. Company Number: 3620776. Vasek Insurance Services Limited is part of the Gallagher group of companies. Contact number: 0115 950 5052. Website: www.insuremyvilla.com.
The purposes and lawful basis of Insure My Villa processing your data We may process your information for a number of different purposes. For each purpose, we must have a legal ground for such processing and we will rely on the following legal grounds:
- The processing is necessary for the performance of a contract with you or to take steps to enter into a contract with you. Your personal information is only used for the purpose of providing quotes, arranging and amending an insurance policy, brokering consumer credit, for the handling of claims, if any.
- The processing is necessary for compliance with a legal or regulatory obligation.
- The processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by your interests, rights or freedoms. You must have an objection to the processing of your personal data on “grounds relating to your particular situation” and we will stop processing the personal data unless:
- we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms; or
- the processing is for the establishment, exercise or defence of legal claims.
We have genuine business needs to use your personal information such as maintaining our business records and keeping records of insurance policies we place and analysing and improving our business model and services, as well as the need to hold records for future liability claims. When using your personal information for these purposes, we have considered your rights and ensured that our business need does not cause you harm.
- We may also request your data for marketing purposes, however we will always obtain your consent to use this data for marketing before doing so. Where you have provided consent, we will send you marketing communications where we think you will be interested in receiving them. You have the right to object to direct marketing at any point and therefore withdraw your consent. An "unsubscribe" link appears in all our marketing emails. To unsubscribe from emails sent by us, simply click on the link at any time. In such circumstances, we will continue where necessary to send you (non-marketing) service related communications.
What personal data we may collect
We may ask for personal data such as; Name, Date of Birth, Addresses, Nationality, Telephone numbers, Occupation, Email address, IP address, Bank Account Name, account number and sort code. Information relating to your previous insurance policies and claims history in order to advise on your future needs, and special categories of information such as Criminal Convictions that are not considered spent under the Rehabilitation of Offenders Act 1974, as this is relevant to the underwriting of your insurance policy. Information captured during recordings of our telephone calls.
The protection of data is something we take extremely seriously. We comply at all times with our statutory obligations regarding data protection in relation to all of our policies. Client information is confidential and is strictly always treated as such. We never, under any circumstances, release information or details about any of our clients or policyholders to anybody else or to any other company, organisation or third party, except where we are instructed to do so by law, when we are arranging insurance on behalf of another insurer, via our live chat facility, or credit on behalf of another consumer credit provider, for the purpose of handling claims or complaints or to selected third parties in connection with the sale, transfer or disposal of our business. These instances may require us to provide relevant information to a third party such as a broker acting on your behalf or other companies who act as insurance distributors, the insurer, independent loss adjusters, Consumer Credit provider, or Regulator/ Supervisory Authority, as well as our third-party services providers such as IT suppliers, Live Chat suppliers, accountants, actuaries, auditors, lawyers, companies within the Purple Bridge Group such as the marketing agency and claims management company, document management providers, tax advisers and insurance software providers.
If you are an insurance agent, affiliate or any other individual or company associated in any way with Insure My Villa then your personal and company information will never be released to anybody else or any other company, organisation or third party. The only time your information may be passed on to others will be if you have asked us to release such information or if we are directed to do so by law.
We do not transfer data outside the European Union, to third countries or international organisations.
When we collect personal information from you
We will obtain your personal information directly from you or from someone else on your behalf in a number of ways including where it is submitted in application forms, initial disclosure documents and more generally during any forms of communication such as email, live chat and telephone. Also from other third parties who might introduce customers to us such as another broker and insurers.
Personal information is collected by us from you when you request any of our online services or you contact us by telephone with a quote request or you wish to purchase an insurance policy or you request to make an amendment to your policy or for the handling of claims, if any. The information we will request from you will be limited to the necessary information required to provide you with the service you have requested. We do not ask for any information that is not necessary or is irrelevant to your individual needs or requirements. Should your personal information change at any time, we would ask you to keep us informed of the change so that our records may stay up to date. We do not obtain your personal data from publicly accessible sources.
Where the provision of personal data is part of a statutory or contractual requirement or obligation, if you fail to provide us with the personal data required, we have the right to terminate the contract we have with you, or refuse insurance on this basis.
You have the right to rectify the personal data we hold if it is inaccurate or incomplete. In these instances, we will inform any third parties of the amendment where possible, and also inform yourself about the third parties to whom the data has been disclosed. We will respond to your request to amend the data within 1 month, or 2 months if the amendment is complex. If we do not fulfil your request, we will explain why this is. You will have the right to complain to the supervisory authority and to a judicial remedy in these instances.
You also have the right to restrict the processing of your personal data when:
- You contest the accuracy of the personal data, we will restrict the processing until we have verified the accuracy of the personal data.
- Where you have objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our organisation’s legitimate grounds override yours.
- When processing is unlawful and you oppose erasure and request restriction instead.
- We no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
We will inform you when we decide to lift the restriction.
How personal information is stored
Personal information that we hold about you is always held securely on our in house computer systems. Information provided through our website is also held securely on dedicated servers and cannot be accessed by any third parties or individuals that are not part of our organisation. All telephone calls received or made by us are recorded for monitoring and training purposes. Our recorded telephone calls are also held on dedicated servers and can only be accessed by senior employees of our organisation. For added security, recorded telephone calls cannot be amended or deleted from the system. All communications via our Live Chat facility are recorded and stored by us and Live Chat Inc.
You have the right to have personal data erased and to prevent processing in specific circumstances:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- When you withdraw consent e.g for receiving marketing material.
- When you object to the processing and there is no overriding legitimate interest for continuing the processing.
- The personal data was unlawfully processed.
- The personal data has to be erased in order to comply with a legal obligation.
There are specific circumstances where the right to erasure does not apply and we can refuse to deal
- To exercise the right of freedom of expression and information;
- To comply with a legal obligation or for the performance of a public interest task or exercise of official authority;
- For public health purposes in the public interest;
- Archiving purposes in the public interest, scientific research historical research or statistical purposes; or
- The exercise or defence of legal claims.
If we have disclosed the personal data in question to third parties, we will inform them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so. We will also do this if the processing of your data is restricted.
Your personal data is only retained by Insure My Villa for as long as necessary. The retention periods
differ based on the type of data processed, the purpose of processing or other factors. These
include where any legal requirements apply for the retention of any particular data. In the absence of
legal requirements, personal data will only be retained by Insure My Villa for as long as necessary for
purpose of processing. This means that your data is to be deleted by us e.g. when:
- you have withdrawn consent to processing; or
- a contract has been performed or cannot be performed anymore; or
- the data is no longer up to date.
Exceptions may also apply to the processing for historical, statistical or scientific purposes.
Debit/credit card details Should you make a payment to us by using either your debit or credit card, then the information you provide for this purpose will not be stored or retained by us. Any and all payments made online are encrypted to prevent fraud and are not stored by us on any of our systems afterwards.
We may pass on your personal data including bank account name, account number and sort code to a third party consumer credit provider, on your request.
Our bespoke website uses an analytical service that records clicks, customer movement, page scrolling
data entered into website forms. This data is collated in order for us to improve our website
The information collected is stored purely for our own aggregated and statistical reporting use and is not shared with any third parties.
Our website also uses software that tracks IP data of companies who visit the website. This information
supplied to us from Whoisvisiting.com. Whoisvisiting.com is a service offered by Whoisdata Limited and
only information available from the public domain.
if you are accessing our website through a business, when you visit our site we may automatically log your company’s IP address, a unique identifier for your computer or other access device. We track the business IP address for security reasons and we will not use your IP address to identify you, the individual, in any way.
There are rights in relation to automated decision making and profiling however we do not use your information for automated decision making including profiling.
Surveys / Reviews
We invite consumers to provide us with feedback on our service. This participation is entirely optional and is purely to gauge and ultimately improve the service offered to our clients. Information collated will not be used for any other purpose, however from time to time we may request to use this information for testimonial purposes in advertising. We will always obtain your permission in doing so.
How you can access the personal information we hold
You have the right of access, meaning the right to obtain confirmation that your data is being processed, access to your personal data and other supplementary information, such as this privacy notice.
You may request to receive a copy of the personal information we hold about you, by making a request in writing. There is currently no charge for this service, however there may be a reasonable fee when a request is manifestly unfounded or excessive. To receive a copy, please write to us requesting the information. All requests will be dealt with within the regulatory time period of within 1 month of receipt. We will be able to extend the period of compliance by a further 2 months where requests are complex or numerous.
You also have the right to data portability, meaning you can obtain and reuse your personal data for your own purposes across different services. We will provide the personal data in a structured, commonly used and machine readable form. However, we do not adopt or maintain processing systems that are technically compatible with other organisations.
If we do not fulfil your request, we will explain why this is. You will have the right to complain to the supervisory authority and to a judicial remedy in these instances without undue delay and at the latest within one month.
There may also be circumstances where exercising some of the rights mentioned (such as the right to erasure, the right to restriction of processing and the right to withdraw consent) will mean your insurance can no longer be provided and it may therefore result in cancellation of your policy. You will therefore lose the right to bring any claim or receive any benefit, including in relation to any event that occurred before you exercised your right of erasure, if our ability to handle the claim has been prejudiced.
Data Protection Officer
If you need to contact the Insure My Villa Data Protection Officer, you can contact:-
Your right to complain
You have a right to complain to the Information Commissioner's Office if you believe that any use of your personal information by us is in breach of applicable data protection laws and/ or regulations. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/ This will not affect any other legal rights or remedies that you have.