Last updated: 16th January 2023
Policy Powerhouse Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our customers and agents and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Policy Powerhouse Ltd. is registered in England under company number 13071685 and are authorised and regulated by the Financial Conduct Authority, FCA registration 946345 as an appointed representative of Innovative Risk Labs Ltd. Innovative Risk Labs Ltd is authorised and regulated by the FCA Registration 609155. You can check this by visiting Financial Services Register or by contacting the FCA on 0800 111 6768.
This Privacy Information explains how we use your personal data, how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Under the UK GDPR Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information is:
We have a legitimate interest to do so.
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Here is a list of ways that we may use your personal information, which of the reasons we rely on to do so and our legitimate interests;
|Purpose / Activity
|Types of Personal Information
|Legal Basis for Processing
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the UK GDPR, you have the following rights, which we will always work to uphold:
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
In order for us to provide insurance quotes, insurance policies, and/or deal with any claims or complaints, we need to collect and process personal data about you. The types of personal data that are processed may include:
We might collect your personal data from various sources, including:
Which of the above sources apply will depend on your particular circumstances.
We will only use your personal data where we are permitted to do so by applicable law. Under EU and UK data protection law, the use of personal data must be justified under one of a number of legal grounds. The principal legal grounds that justify our use of your personal data are:
We may use your data in the following ways. In each case, we note the grounds that we rely on to your use your personal data.
Please note that in addition to the disclosures we have identified against each purpose, we may also disclose personal data for those purposes to our service providers, contractors, agents and group companies that perform activities on our behalf.
We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and you will always have the opportunity to opt-out where appropriate.
In order to provide insurance cover and deal with insurance claims in certain circumstances insurance market participants may need to process your special categories of personal data, such as medical and criminal convictions records, as set out against the relevant purpose. Your consent to this processing may be necessary for the insurance market participant to achieve this.
We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim under this insurance, or where we are required to keep your personal data due to legal or regulatory reasons.
We may need to transfer your data to insurance market participants or their affiliates or sub-contractors which are located outside of the European Economic Area (EEA). Those transfers would always be made in compliance with the GDPR. If you would like further details of how your personal data would be protected if transferred outside the EEA, please contact the data protection contact of the relevant participant. We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
The insurance lifecycle involves the sharing of your personal data between insurance market participants, some of which you will not have direct contact with. The identity of the insurance market participants will be the insurer on your insurance documents. We may have used more than one insurance participant to get the best product for you and upon request can advise you of who we consulted prior to your insurance contract placement with the initial data controller.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details: Policy Powerhouse Ltd, The Granary, Hermitage Court, Hermitage Lane, Maidstone, Kent, ME16 9NT. Tel: 0333 772 7453 Email: firstname.lastname@example.org.
If you have any concerns about our use of your personal information, you can make a complaint to us at the above address.
You can complain to the ICO if you are unhappy with how we have used your data;
The ICO’s address:
Information Commissioners Office, Wycliff House, Water Lane, Wilmslow, Cheshire. SK9 5AF
Helpline number: 0303 123 1113 website: https://www.ico.org.uk
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.