Centor Privacy Notice
For the purposes of data protection legislation, the Data Controller is Centor Insurance & Risk Management Ltd, 1 Great Tower Street, London EC3R 5AA. Our Data Protection Manager is Oriel Gavin. If you have any queries, complaints or requests, please contact Oriel on email@example.com or 0207 330 8714.
What information we collect from you
We will collect and process the following data about you:
- Information you give us. This is information about yourself that you give us by filling in forms on our site or by corresponding with us by phone, email or otherwise. It may include your name, address, phone number, email address and financial information, as well as special category data, such as medical or criminal convictions information.
- Information we collect from your use of our Site. When you visit our Site, we will automatically collect the following information:Technical information including your IP address, what type of device you used to visit our site, and what pages within the site you accessed and when.
- Technical information including your IP address, what type of device you used to visit our site, and what pages within the site you accessed and when.
- We collect your telephone number when you call us and, in some circumstances, the name of the person associated with this telephone number for direct dialling purposes.
Why we collect this information
We use this information in the following ways:
- Information you give us. We use this information:
- To undertake our primary function as an insurance intermediary for which you would enter into a contractual agreement with us as well as an insurance provider if you proceed to purchase insurance products through us.
- To take steps necessary to assess whether we can enter into a contract with you and in order to perform our contract with you.
- To improve our service to you, ensuring that content on our site is presented in the most effective manner for you and your device.
- To deal with any legal queries related to your use of our service.
- To provide you with service communications so that you receive a full and functional service and so we can perform our obligations to you. These may be sent by email, post, or by phone. These will include notifications about changes to our service.
- To provide our existing clients with marketing communications, including information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
- To carry out our obligations arising from any contracts entered into by you and us.
Lawful Basis of Processing – Not Direct Marketing
- We will process your data on the grounds of performance of a contract and legitimate interest.
- Where we process special category data, such as medical or criminal conviction information, in addition to performance of a contract, processing will be on the grounds of ‘necessary for the purpose of insurance‘, created by the Data Protection Bill, Article 9 (2)(g).
Lawful Basis of Processing – Direct Marketing
- If you are already a client of ours, or have been in the past, we may send you information from time to time on some of our other services and articles we think might be of interest to you, based on legitimate interest.
- If you have never been a client of ours, we will seek to obtain consent from you to continue to send marketing communications from us. If granted, you can withdraw this consent at any time.
Information we collect from your use of the Site.
We will use this information for the following purposes:
- To administer our Site and for internal operations, including data analysis, testing, research, statistical and survey purposes.
- To improve our Site to ensure we present the most relevant content, and to ensure it is presented in the most effective manner for you and your device.
- As part of our efforts to keep our site safe and secure.
How long we keep hold of your information
- Whilst you are a client of ours, we will keep some or all of your data for the duration of the contract.
- When you cease to become a client of ours, we will keep data for a maximum of seven years, unless the contract was for employer’s liability in which case, we will keep limited data, for a maximum of 10 years, to facilitate the management of claims.
- Where you have asked us to provide insurance services, such as quotations and you do not then become a client of ours, we will keep your data for a maximum of three years..
Who we might share your information with
You agree that for the purposes set out in the ‘Why we collect this information’ section above, we have the right to share your personal information with:
- Selected associated third parties whom we appoint to provide services, including:
- Insurers, business partners and suppliers, for the performance of any contract we enter into with you.
- Analytics and search engine providers that assist us in the improvement and optimisation of our Site
- Customer survey providers in order to receive feedback and improve our services
We will never sell your information to third parties. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
How we protect your information
We take your safety and security very seriously and are committed to protecting your personal and financial information. We do transfer your data outside the European Economic Area (EEA), more specifically to Canada for the purposes of email archiving only. We can assure you that there are adequate protection measures in place under at Data Protection Agreement that ensure you still benefit form EEA data protection legislation.
Some insurers we work with have advised us that they do transfer data outside the EEA, if you would like to know if this affects you directly, please contact us and we can deal with your enquiry on an individual basis. Where insurers have indicated they do transfer outside the EEA they have provided assurances that adequate protection measures are in place to comply with the UK Data Protection Regulations.
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Where processing of your personal data is based on consent, you can withdraw consent at any time. In addition, you have the following rights, which you can exercise at any time:
You have the right:
- To ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes. If you would not like your data to be used for marketing purposes, you can withdraw from any further communications at any time, by unsubscribing using the link at the bottom of marketing communications, or by emailing us at firstname.lastname@example.org.
- To ask us not to process your personal data where it is processed on the basis of legitimate interests, provided that there are no compelling reasons for that processing;
- To ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, or you have withdrawn consent (if the legal basis for processing is consent), or you exercise your right to object (if the data is unlawfully processed) or the data needs to be erased to comply with a legal obligation.
- To ask for the information we hold about you to be rectified if it is inaccurate or incomplete.
- To receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, within one month of request, which can be extended by us to three months for more complex cases.
You can exercise your rights by contacting our Data Protection Manager Oriel Gavin at Centor Insurance & Risk Management Ltd, 1 Great Tower Street, London EC3R 5AA, or emailing email@example.com or firstname.lastname@example.org.
Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above. In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, which is the Information Commissioner’s Office (ICO), at any time. The ICO’s contact details are available here: https://ico.org.uk/concerns
How you can access and update your information
If you want to update the information we hold about you, you can email us at email@example.com or write to us at Centor Insurance & Risk Management Ltd, 1 Great Tower Street, London EC3R 5AA. You have the right to ask for a copy of the information we hold about you and we will provide it free of charge.
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Centor Insurance & Risk Management Ltd
1 Great Tower Street, London EC3R 5AA
Telephone: +44 (0) 207 256 7300
Updated June 2019