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Privacy Policy

Company Information

Ashley Page Insurance Brokers Limited (Company registration number 502367. FCA registration number 300631) are insurance brokers, specialising in private client and commercial insurance.  Ashley Page Financial Services Limited. (Company registration number 1559128. FCA registration number 131637) provide independent financial advice, including mortgage advice and life assurance. The two companies offer complimentary services.  There is no systematic sharing or processing of data between the two organisations, although data may be shared for marketing purposes. 

Privacy Policy

This privacy policy tells you what to expect when Ashley Page Insurance Brokers Limited and Ashley Page Financial Services Limited collects and processes your personal information. We take the protection of your data seriously and are committed to being transparent with you about the data we collect and how it is used and shared. We are committed to ensuring that we meet all our obligations under relevant Data Protection laws, including the United Kingdom (UK) and European Union (EU) General Data Protection Regulations (GDPR) and UK Data Protection Act 2018, as amended from time to time.

Contents

  1. Personal Information we collect
  2. How and why we use this information
  3. Where we obtain your information
  4. How we share this information
  5. Retention of your personal data
  6. Security
  7. International Data Transfers
  8. Your rights
  9. Cookies and similar technologies
  10. Acceptable use
  11. External Links
  12. Information relating to employment
  13. Who to contact about your Personal Data
  14. Changes to our privacy notice

Personal Information we collect

We will receive personal information about you when you contact us, for example by requesting or obtaining a quote, purchasing a product from us or from one of our partners or using one of our websites.  The information may include:

Individual details

Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you.

Identification details

Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number.

Financial information

Payment card number (credit or debit card), bank account number, or other financial account number and account details, credit history, credit reference information and credit score, assets, income, and other financial information, account log-in information and passwords for accessing insurance policy, claim and other accounts.

Risk details

Information about you (and others insured under the policy) which we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to health, criminal convictions, or other special categories of personal data (see below). For certain types of policy, this could also include telematics data.

Policy information

Information about the quotes you receive and policies you take out.

Credit and anti-fraud data

Credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you.

Medical condition and health status

Current or previous physical, mental or medical condition, health status, injury or disability information, medical diagnosis, medical procedures performed and treatment given, personal habits (for example, smoking or consumption of alcohol), prescription information, and medical history.

Previous and current claims

Information about previous and current claims, (including other unrelated insurances), which may include data relating to your health, criminal convictions, or other special categories of personal data (see below) and in some cases, surveillance reports.

Other sensitive information

Information about religious beliefs, ethnicity, political opinions or trade union membership, sexual life and orientation, or genetic or biometric information

We may obtain information about criminal records or civil litigation history (for example, for preventing, detecting and investigating fraud)

Telephone recordings

Recordings of telephone calls with our representatives

Photographs and video recordings

Images (including photographs and pictures) or video recordings created in connection with our insurance or other business activities, including for claims assessment, administration and settlement, claim disputes, or for other relevant purposes as permitted by law, as well as CCTV recordings captured by equipment on our premises

Marketing preferences and marketing activities

Marketing preferences including preferences for our method of contact.

To improve our marketing communications, we may collect information about interaction with, and responses to, our marketing communications

How and why we use this information

We will process any personal data lawfully under one or more of the following bases:

Performance of a Contract

The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

Compliance with a Legal obligation

The processing is necessary for us to comply with the law (not including contractual obligations).

The processing is necessary for our legitimate interests pursued by us. In such cases our legitimate interests are as follows:

Legitimate interests

To add value to your product by offering you other general insurance products;

To provide high standards of service to our customers by ensuring they are fully informed about all of our products;

To engage in activities to improve and adapt the range of products and services we offer and to help our business grow;

To investigate and prevent potential fraudulent and other illegal activity.

Consent

Where you have given clear consent for us to process your personal data for a specific purpose, such as marketing activities. If we need consent to process personal information, we’ll ask for this first. This consent can be withdrawn at any time.

Necessary for reasons of substantial public interest

Under the UK Data Protection Act 2018 processing for an insurance purpose is included within this basis when processing special category and conviction data.

We will use personal information about you primarily in connection with the provision of insurance, namely:

  • Establishing and maintaining communications with you;
  • Comply with applicable legal, regulatory and professional obligations, including cooperating with regulatory bodies and government authorities, to comply with law enforcement and to manage legal claims;
  • Make assessments and take decisions, including whether to pay your claim or pursue any losses against you or a third party, provide you with our products and services, on what terms and whether you are eligible for a payment plan;
  • Arranging insurance cover (issuing quotations, renewals, policy administration);
  • Handling claims;
  • Undertaking anti-fraud, sanction, anti-money laundering and other checks to protect against fraud, suspicious or other illegal activities;
  • Process payments when you purchase a product or service and any refunds;
  • Collecting, forwarding and refunding premiums;
  • Facilitating premium finance arrangements;
  • Processing transactions through service providers;
  • Credit assessments and other background checks;
  • Where we believe it is necessary to meet legal, security, processing and regulatory requirements;
  • Business transfers where we sell whole or part of our business and/or assets to a third party purchaser to allow the purchaser to administer your insurances;
  • Marketing and client profiling;
  • Allowing our group and associated companies to notify you of certain products or services offered by them;
  • Research and statistical analysis; and
  • Building databases for use by us and others we may share information with.
  • Manage relationships with third parties, e.g. brokers and service providers;
  • Improve our products and services, provide staff training and maintain information security, including by recording and monitoring telephone calls;
  • Conduct customer analysis, market research and focus groups, including customer segmentation, campaign planning, creating promotional materials, gathering customer feedback and customer satisfaction surveys;
  • Manage complaints, including to allow us to respond to any current complaints, or challenges you or others might raise later, for internal training and monitoring purposes and to help us to improve our complaints handling processes. We may be obliged to forward details about your complaints, including your Personal Information, to the appropriate authorities, e.g. the relevant ombudsman;

We may monitor calls, emails, text messages and other communications with you.  When you contact us we may keep a record of that correspondence and any information provided to us during that or any subsequent communication.

We may use your purchase history to tell you about our offers and products that we think you will be most interested in.  If you prefer not to receive these messages, you can opt out at any time.

If you’ve chosen to receive marketing information from us, profiling and automated decision making may be used to make our marketing more relevant, for example by personalising the methods we use to market to you, the marketing messages you receive and the offers you’re sent.

Where we obtain your information

We will collect personal information about you from you directly but also potentially from your family members, employer or representative, other insurance market participants, credit reference agencies, anti-fraud databases, sanctions lists, court judgements and other judicial databases, government agencies such as the DVLA and HMRC, open electoral register and any other publicly available data sources.  In addition, in the event of a claim, we will receive information from third parties including the other party to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, solicitors, and claims handlers.

How we share this information

In using personal data for the above purposes, we may disclose personal data to third parties including (but not limited to) insurers, reinsurers, intermediaries or other brokers; outsourcers, sub-contractors, agents and service providers; claim handlers; premium finance providers; professional advisers and auditors.  Third parties to whom we disclose personal data are required by law and contractual undertakings to keep personal data confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances and in compliance with all applicable legislation.

We may share and aggregate information about you from across Ashley Page Insurance Brokers Limited and Ashley Page Financial Services Limited, including personal information relating to other policies held with us, quotes or claims details and we may use this information to:

  • help us identify products and services that could be of interest to you, to tailor and package our products and services; to determine pricing and/or offer available discounts; and
  • conduct customer research and develop marketing campaigns.

Retention of your personal data

We keep Personal Information for as long as is reasonably required for the purposes explained in this Privacy Policy. We also keep records, which may include Personal Information, to meet legal, regulatory, tax or accounting needs. For example, we are required to retain an accurate record of your dealings with us, so we can respond to any complaints or challenges you or others might raise later. We’ll also retain files if we reasonably believe there is a prospect of litigation. The specific retention period for your Personal Information will depend on your relationship with us and the reasons we hold your Personal Information.

To support us in managing how long we hold your data and our record management, we maintain a data retention policy which includes clear guidelines on data retention and deletion.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. We may need to transfer your information outside the United Kingdom to other service providers and business partners. We will only transfer your personal information in this way where there is an adequate level of protection that is the same as the level of protection required under United Kingdom data protection legislation.

We have adopted the technical and organisational measures necessary to ensure the security of the personal data we collect, use and maintain, and prevent their alteration, loss, unauthorised processing or access, having regard to the state of the art, the nature of the data stored and the risks to which they are exposed by virtue of human action or physical or natural environment. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that personal information you supply will not be intercepted while being transmitted to us over the internet. We ask that you do your part by maintaining in strict confidence any computer passwords you use to access the Internet or this Site. We encourage responsible reporting of any vulnerabilities that may be found in our Sites or any application available through our Sites.

International Data Transfers

In the event that we process personal information outside the UK, the processing in those locations is protected by UK and European data standards. If the information you provide to us is transferred to countries outside the UK and the European Economic Area (EEA) by us or our suppliers, steps will be taken to make sure appropriate security measures are in place with the aim of ensuring your privacy rights continue to be protected.

Your rights

Data protection laws provide you with a number of rights as set out below.

We may ask you for proof of identity when you make a request to exercise any of these rights. We do this to ensure we only disclose information to the right individual.

We aim to respond to all valid requests within one calendar month. It may take us longer if the request is particularly complicated or you have made several requests. We’ll always let you know if we think a response will take longer than one calendar month. We may also ask you to provide more detail about what you want to receive or are concerned about.

We may not always be able to do what you have asked. This is because your rights will not always apply, for example if it would impact the duty of confidentiality we owe to others, or if the law allows us to deal with the request in a different way. We will always explain to you how we are dealing with your request.

Right to access your personal data

You may request confirmation that we hold personal data about you, as well as access to a copy of any such data.

Right to rectification

You may ask us to rectify any inaccurate information we hold about you.

Right to erasure

You may ask us to erase your Personal Information, but this right only applies in certain circumstances, e.g. where:

  • it is no longer necessary for us to use your Personal Information for the original purpose;
  • our lawful basis for using your Personal Information is consent and you withdraw your consent; or

our lawful basis is legitimate interests and there is no overriding legitimate interest to continue using your Personal Information if you object

This isn’t an absolute right and we have to balance your request against other factors such as legal or regulatory requirements, which may mean we cannot erase your Personal Information.

Right to restriction

You may ask us to stop using your Personal Information in certain circumstances such as:

  • where you have contacted us about the accuracy of your Personal Information and we are checking the accuracy;
  • if you have objected to your Personal Information being used based on legitimate interests.

This isn’t an absolute right and we may not be able to comply with your request.

Right to portability

  • we have justified our use of your Personal Information based on your consent or the performance of a contract with you; and our use of your Personal Information is by electronic means.

Right to object

You can object if you no longer wish to receive direct marketing from us.

You may also object where you have grounds relating to your particular situation and the lawful basis we rely on for using your Personal Information is our (or a third party’s) legitimate interests. However, we may continue to use your Personal Information where there are compelling legitimate grounds to do so.

You have the right not to be subject to a decision using your Personal Information which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right does not apply if the decision is:

  • Automated decision making necessary for the purposes of a contract between us and you;
  • authorised by law (e.g. to prevent fraud); or
  • based on your explicit consent.

You do however have a right to request human intervention, express your view and challenge the decision.

Right to make a complaint

You have the right to lodge a complaint with the supervisory authority (although we would encourage you to contact us in the first instance).

The Information Commissioner can be contacted at;

Information Commissioners Office, Wycliffe house, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk  

Cookies and similar technologies

Like many companies, we may use cookies on this Site. Cookies are pieces of information shared between your web browser and a website. Use of cookies enables a faster and easier experience for the user. The only personal information a cookie can contain is information you supply. A cookie cannot read data off your computer’s hard drive. There are different kinds of cookies with different functions:

(i) Session cookies:

these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.

(ii) Persistent cookies:

a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.

(iii) First-party cookies:

the function of this type of cookie is to retain your preferences for a particular website. They are stored and sent between the server and your computer’s hard drive. They are not used for anything other than for personalisation as set by you. We never use third-party or unsatisfactory cookies on our Sites, although we do use third party provided web beacons (please see the section on Web Beacons). For information on all of these categories of cookies, and for more information generally on cookies please refer to aboutcookies.org. We use cookies for the following purposes:

Where strictly necessary

These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as obtaining a quote or logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

Performance

These cookies collect information about how visitors use a Site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that our Site works. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our Site works.

Functionality

These cookies allow our Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a Site may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Site. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the internet. Please consult your web browser’s ‘Help’ documentation or visit aboutcookies.org for more information about how to turn cookies on and off for your browser. We use Google Analytics to help us collate Site statistics. For further details on the cookies set by Google Analytics, please refer to the Google Code website.

Web Beacons

This Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with e-mails from Ashley Page. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about Ashley Page and our services. We will conduct this review on an anonymous basis.

IP Addresses

When you visit our Sites, Ashley Page collects your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, Ashley Page uses IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you can not be identified from the IP address. If you do not wish your IP address to be stored, please opt out by contact us by using the contact details at the bottom of this Privacy policy.

Acceptable use 

If you leave a comment on any Ashley Page content or participate in an Ashley Page discussion forum or chat room, we ask that you must do so in accordance with spirit of the following standards:

  • Please be accurate and/or genuine in your comments.
  • Please stay within the applicable law of your country – don’t use this Site to post defamatory, obscene, offensive, hateful or inflammatory content.
  • Don’t infringe the intellectual property rights (for example copyright, trademarks or database rights) of others.

Each participant’s opinion is his or her own and should not be considered as reflecting the opinion of Ashley Page.  We will transfer your comments to employees of Ashley Page who shall monitor the comments made on the website.

External links

Ashley Page may include links to other websites whose privacy policies we do not control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your web browser), use of any personal information you provide is governed by the privacy policy of the operator of the website you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these websites via a link from the website’s homepage, you should contact the website directly for more information.

Information related to employment

This Site may provide an opportunity to submit your curriculum vitae or an application form to us or apply for a position through this Site. If you submit information for such purposes, we will use (which may include transferring) the personal information you provide to evaluate your qualifications and contact you regarding any positions at Ashley Page or any of its affiliated companies in which we believe you may be interested.  We may pass your personal information to other members of Ashley Page group of companies for the purposes of considering your application. This will involve transferring your personal information to our employees who will process your application on our behalf.

Who to contact about your Personal Data

Privacy Policy questions should be directed to us via our contact form or by writing to the following address:

Ashley page Insurance Brokers Ltd, Ground Floor, Gallery Court, 28 Arcadia Avenue, London, N3 2TN.

Changes to our privacy policy

This Privacy Policy was last updated on 21/12/2023.

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business activities, legal requirements, and the manner in which we process Personal Information.  We will place updates on this website and where appropriate we will give reasonable notice of any changes.



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