We Primo plc (also referred to as “we”, “us”, or “our”) are a registered company in England (Company no. 1008700). Our registered address is Cumberland House, Baxter Avenue, Southend-on-Sea, Essex, SS2 6HZ.
THE PURPOSE OF THIS NOTICE
This Notice is designed to help you understand what kind of information we collect in connection with our products and services and how we will process and use this information. In the course of providing you with products and services, we will collect and process information that is commonly known as personal data.
This Notice describes how we collect, use, share, retain and safeguard personal data.
This Notice sets out your individual rights; we explain these later in the Notice, but in summary, these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
WHAT IS PERSONAL DATA?
Personal data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, their gender and contact details.
Personal data may contain information which is known as special categories of personal data. This may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to or sexual orientation.
Personal data may also contain data relating to criminal convictions and offences.
For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.
PERSONAL DATA WE COLLECT
In order for us to arrange and administer insurance for you, we will collect and process personal data about you. We will also collect your personal data where you request information about our services, customer events, promotions and campaigns.
We may also need to collect personal data relating to others in order to arrange and administer insurance. In most circumstances, you will provide us with this information. Where you disclose the personal data of others, you must ensure you are entitled to do so.
You may provide us with personal data when completing an online quote or contact forms, when you contact us via the telephone, when writing to us directly or where we provide you with paper-based forms for completion, or we complete a form in conjunction with you.
We will share your personal data with our firm and with business partners. This is normal practice within the insurance industry where it is necessary to share information in order to place, quantify and underwrite risks, to assess overall risk exposure and to process claims. It is also necessary to determine the premium payable and to administer our business.
We also share personal data with authorised third parties, and this is necessary where we are required to do so by law, where we need to administer our business, to quote for, source, place and administer your insurances (including arranging insurance premium finance) to perform underwriting activities and to process claims. Some examples follow:
- Premium finance providers;
- Credit reference agencies;
- Debt recovery agencies;
- Claims handling companies;
- Loss adjusters;
- Insurance brokers;
- Sanctions checking agencies;
We will collect your personal data when you visit our website, where we will collect your unique online electronic identifier; this is commonly known as an IP address.
We may record your communications with us when contacting our customer care, complaints and other customer-focused functions. Where we collect data directly from you, we are considered to be the controller of that data, i.e. we are the data controller.
Where we use third parties to process your data, these parties are known as processors of your personal data. Where there are other parties involved in underwriting or administering your insurance they may also process your data in which circumstance we will be a joint data controller of your personal data.
A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data.
A data ‘processor’ means the individual or organisation which processes personal data on behalf of the controller.
As a provider of insurance services, we will process the following categories of data:
- Personal data such as an individual’s name, address, date of birth, gender, contact details and details of historical claims
- Special categories of personal data such as health and details on historical claims resulting in injury (physical and physiological)
- Data relating to criminal convictions and offences such as details of driving offences or insurance fraud
If you object to the collection, sharing and use of your personal data we may be unable to provide you with our products and services.
For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place.
WHY DO WE NEED YOUR PERSONAL DATA?
We will use your personal data for the performance of our contract with you, to quote for and provide you with insurance products and services, to process claims and renewals, to administer your policy and our business, to respond to any requests from you about services we provide and to process complaints.
We will also use your personal data to manage your account, perform statistical analysis on the data we collect, for financial planning and business forecasting purposes and to develop new and market existing products and services.
We will use the special category and criminal conviction data we collect about you for the performance of our contract with you which is deemed to be necessary for reasons of substantial public interest.
This allows us to quote for and provide you with insurance products and services, to process claims and renewals and to administer your policy. In purchasing our products and services, you should understand that you are forming a contract with us.
If you contact us for a quote or request details on the services we provide, we consider ourselves as having a legitimate business interest to provide you with further information about our services.
In some situations we may request your consent to market our products and services to you, to share your data or to transfer your data outside the European Economic Area. Where we require consent, your rights and what you are consenting to will be clearly communicated to you.
Where you provide consent, you can withdraw this at any time by contacting our data privacy representative.
We will retain your personal data at the end of any contractual agreement for a period of 7 years. We will retain special category and criminal conviction data for a period of 7 years.
Where you have submitted a claim, we will retain your data for a period of 7 years if it is a non-injury claim; where an individual has been injured (physical and physiological), we will retain your data indefinitely.
Where you have requested a quote, we will retain your personal data for seven years, where you have contacted us for details of our services and products, we will retain your personal data for seven years. Where you make a complaint, we will retain the data for seven years.
Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.
The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis and product development and marketing purposes.
Sometimes we may need to retain your data for longer, for example, if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
We will transfer your data to third parties based outside the European Economic Area.
This is necessary for the purposes of administering our business and underwriting and claims processing purposes.
Such parties are not permitted to use your personal data for any other purpose than for what has been agreed with us. These parties are also required to safeguard your personal data through the use of appropriate technical and organisational data security measures and are prohibited from disclosing or sharing your data with other third parties without our prior authorisation, or unless as required by law.
Please contact our data privacy representative for a list of countries and organisations your personal data is transferred to and/or for further information on the measures undertaken to safeguard your data.
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
- The right to be informed about the personal data being processed;
- The right of access to your personal data;
- The right to object to the processing of your personal data;
- The right to restrict the processing of your personal data;
- The right to rectification of your personal data;
- The right to erasure of your personal data;
- The right to data portability (to receive an electronic copy of your personal data);
Rights relating to automated decision making including profiling.
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests. However, if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example, if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.
You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health-related matters.
The flow of data within the insurance sector is complex, and we ask you to keep this in mind when exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations to help satisfy your request this may impact on timescales.
PROTECTING YOUR DATA
We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data with our firm, and authorised third parties.
DATA PRIVACY REPRESENTATIVE
If you are dissatisfied with any aspect of the way in which we process your personal data, please contact data privacy representative. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office(ICO).
The ICO may be contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.
HOW TO CONTACT US