​​Definitions and Interpretation

1. In this privacy policy, the following definitions are used: -

• Data - collectively all information that you submit to Addept Insurance Services via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.

• Cookies - a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies).

• Data Protection Laws - any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation.

• GDPR - the UK General Data Protection Regulation.

• Addept Insurance Services, We or Us - Addept Insurance Services, London, UK

• UK and EU Cookie Law - the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018.

• User or You - any third party that accesses the Website and is not either 

  • (i) employed by Addept Insurance Services and acting in the course of their employment or 

  • (ii) engaged as a consultant or otherwise providing services to Addept Insurance Services and accessing the Website in connection with the provision of such services.

• Website - the website that you are currently using, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

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2. In this privacy policy, unless the context requires a different interpretation: -

• the singular includes the plural and vice versa;

• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

• a reference to a person includes firms, companies, government entities, trusts and partnerships;

• "including" is understood to mean "including without limitation";

• reference to any statutory provision includes any modification or amendment of it;

the headings and sub-headings do not form part of this privacy policy.

Scope of this Privacy Policy

This privacy policy applies only to the actions of Addept Insurance Services and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

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For purposes of the applicable Data Protection Laws, Addept Insurance Services is the "data controller". This means that Addept Insurance Services determines the purposes for which, and the way, your Data is processed.
 
Data Collected

We may collect the following Data, which includes personal Data, from you: -

• name;

• contact information such as email addresses and telephone numbers;

in each case, in accordance with this privacy policy.

 

How we Collect Data

We collect Data in the following ways: -

• data is given to us by you; and

• data is collected automatically.

 
Data that is Given to Us by You

Addept Insurance Services will collect your Data in several ways, for example: -

• when you contact us through the Website, by telephone, post, e-mail or through any other means;

• when you make payments to us, through this Website or otherwise;

• when you use our services;

in each case, in accordance with this privacy policy.

 

Data that is Collected Automatically

To the extent that you access the Website, we will collect your Data automatically, for example: -

• we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

• we will collect your Data automatically via cookies, in line with the cookie settings on your browser.

for more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
 
Our Use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons: - 

• internal record keeping;

• improvement of our products / services;

in each case, in accordance with this privacy policy.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

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Keeping Data Secure

We will use technical and organisational measures to safeguard your Data, for example: -

• access to your account is controlled by a password and a user name that is unique to you.

• we store your Data on secure servers.

This site has been built using Wix.  Wix are certified to ISO 27001. This family of standards helps us manage your Data and keep it secure.

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Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via email.

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If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
 
Data Retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

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Your Rights

You have the following rights in relation to your Data: -

• Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

• Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.

• Right to erase - the right to request that we delete or remove your Data from our systems.

• Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.

• Right to data portability - the right to request that we move, copy or transfer your Data.

• Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

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To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via e-mail.

 

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

 

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

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Links to Other Websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

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Changes of Business Ownership and Control

Addept Insurance Services may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Addept Insurance Services. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

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We may also disclose Data to a prospective purchaser of our business or any part of it.

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In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

This Website may place and access certain Cookies on your computer. Addept Insurance Services uses Cookies to improve your experience of using the Website and to improve our range of services. Addept Insurance Services has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

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All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

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Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Addept Insurance Services to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

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This Website may place the following Cookies: -

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookie.

 

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please see the help menu in your internet browser. You can switch off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly and efficiently.

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You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

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It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
 

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

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If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

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Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

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This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
 
Changes to this Privacy Policy

Addept Insurance Services reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.
 
Privacy Notice

Addept Insurance Services is not a retail provider, therefore we will not collect any data direct from any individual as we currently do not have any direct contact with customers.

We will be provided with customer data from our distribution partners and insurers.

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This privacy notice is in place for if and when we start to receive data directly from customers. 

How will we use the information given to us?
We will use information given to us; to provide an insurance Contract and help you make a claim. This includes providing you with a quotation, arranging and administering your policy, renewals and adjustments. We may require special category data from you, such as health or criminal conviction information. We do so on the basis that it is in the public interest for insurance to be available to you, and to fight crime.

As we are a regulated firm, your data will be used to ensure we meet legal and regulatory requirements. We also have a legitimate interest in using your data for business operations to ensure we can continue to provide insurance to you.
We may use your data to send you marketing information. This will either be on the basis that we have a legitimate interest to do so, or where you have consented. You will be able to withdraw your consent or unsubscribe easily at any time from these communications.

We also need to use your information to process payments, collect debts, and provide premium finance. This may include credit checks. This is also to provide an insurance Contract to you, or as we have a legitimate interest in providing these services and collecting debts.
 

Purpose of Processing: Insurance quotations, arranging and administering Insurance, claims, renewals and adjustments  

Types of Personal Data: Names, Addresses, Risk Information    

Lawful Basis: Performance of a Contract

 

Purpose of Processing: Insurance quotations, arranging and administering Insurance, claims, renewals and adjustments

Types of Personal Data: Special Categories including Health and Criminal Convictions

Lawful Basis: Substantial Public Interest

 

Purpose of Processing: Legal and Regulatory compliance

Types of Personal Data: Names, Addresses, Risk Information

Lawful Basis: Compliance with a Legal Obligation

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Purpose of Processing: Legal and Regulatory compliance

Types of Personal Data: Special Categories including Health and Criminal Convictions

Lawful Basis: Substantial Public Interest

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Purpose of Processing: Business operations and administration

Types of Personal Data: Names, Addresses, Risk Information

Lawful Basis: Legitimate Interest 

 

Purpose of Processing: Business operations and administration

Types of Personal Data: Special Categories including Health and Criminal Convictions

Lawful Basis: Substantial Public Interest

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Purpose of Processing: Marketing

Types of Personal Data: Names, Contact Details, Marketing Preferences

Lawful Basis: Legitimate Interest or Consent

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Purpose of Processing: Payments, debts, Premium Finance

Types of Personal Data: Name, Address, Bank Details & Credit/Debit Card, Credit History

Lawful Basis: Performance of a Contract or Legitimate Interest

Who will we share your data with?
To provide insurance, these firms will be Insurers, other insurance brokers, price comparison sites and firms handling claims. To meet our legal and regulatory obligations, they include regulatory bodies, legal and compliance services providers, fraud agencies and databases. To help run our operations including marketing, they include firms that provide information technology support to us. For payments, this includes finance providers, debt recovery, and payment services providers.

 

The type of personal information we collect. 
We currently collect and process the following information: -

• Your name, address, date of birth, telephone numbers and email address.

• Your unique membership, policy or plan number for the product that you have that provides you with access to the services that we provide.

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How we get your personal information and why we collect it.
Most of the personal information we process is provided to us directly by you for the following reasons: -

• To access the services that we have agreed to provide to you under the membership, policy or plan to which you are entitled. 

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We also receive personal information indirectly, from the following sources in the following scenario: -

• Where we use external parties to provide our services to you, they will advise us that you have accessed the service and provide us with your personal information.

 

We use the information that you have given us to: -

• Ensure that you are entitled to use the service.

• Monitor the level of service and accuracy provided to you.

 

We may share this information with the organisation that provided you with the membership, policy or plan that entitled you to use our service.

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are: 

• Your consent. You can remove your consent at any time. You can do this by contacting enquiries@addeptgroup.co.uk. This may however affect our ability to provide our service to you.

• We have a contractual obligation.

• We have a vital interest.

• We have a legitimate interest.

 

How we store your personal information. 
Your information is securely stored using Microsoft’s OneDrive cloud-based storage. OneDrive uses 256-bit AES encryption to protect your data in transit and at rest. This is a robust encryption method that is widely used to secure data.  

We keep personal information for seven years. We will then systematically dispose of this information by permanently deleting the data from Microsoft OneDrive.

 

Your data protection rights.
Under data protection law, you have rights including: -

• Your right of access - You have the right to ask us for copies of your personal information. 

• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 

• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

• Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

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You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at enquiries@addeptgroup.co.uk or 020 4570 6102 or Level 30, The Leadenhall Building, 122 Leadenhall Street, London EC3V 4AB if you wish to make a request.

 

How to complain.
If you have any concerns about our use of your personal information, you can make a complaint to us at enquiries@addeptgroup.co.uk.
 

You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:            
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk