Welcome to Assured Cyber’s privacy policy.
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you how we look after your personal data when you visit our website (regardless of where you visit from) and tell you about your privacy rights and how the law protects you.
Purpose of this privacy policy
This privacy policy aims to give you information on how Assured Cyber Ltd collects and processes your personal data in the context of Assured Cyber’s provision of its insurance broking services to you or your business, through your use of this website and through any other ways we interact with you, as set out in more detail in Paragraph 3 below.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy, together with any other privacy notice or policy (or fair processing notice or policy) we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.
About us
Assured Cyber Ltd is an insurance broker authorised and regulated by the Financial Conduct Authority.
Assured Cyber Ltd is the controller and responsible for your personal data (collectively referred to as “Assured”, “we”, “us” or “our” in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Assured Cyber Ltd
Email address: henry@assured.co.uk
Postal address: Copthall House, Copthall Avenue, London, EC2R 7DJ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 24th August 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The Data We Collect About You
For Assured to provide insurance quotes, insurance policies and/or deal with any claims or complaints, we may need to collect, retain and process certain personal data about you and/or your employees.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you while arranging insurance cover for you or managing a claim. We have grouped the personal data together as follows:
- Identity Data includes name, title, job title, and employer details.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details, and sanctions checks.
- Risk Data includes information about your company which we and other market participants need to collect to assess the risk to be insured and provide a quote.
- Claims Data includes information about your company’s previous and current claims (including other unrelated insurances).
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
In some cases, companies seeking to use our services may be required to share the Identity and Contact Data of their employees. This personal data will be processed for the purpose of quotation and inception (as set out in the table below). We will process this personal data where it is necessary for the performance of a contract with you.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
- Identity, Financial and Risk Data from credit reference and fraud prevention agencies, and courts.
How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We may share your personal data with the parties set out below for the purposes set out in the table below.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your personal data will never be sold on to external parties or organisations for marketing purposes.
| Purpose/Activity | Lawful basis for processing including basis of legitimate interest | Possible third party disclosures |
|---|---|---|
| Quotation and inception | ||
| (a) Establishing a client relationship
(b) To evaluate, process and complete your requests and/or applications for our products and services (c) For security and verification of your identity (d) Performing credit or money laundering checks or other checks required by law |
(a) Performance of a contract with you
(b) Complying with a legal obligation (c) Legitimate interest (to confirm client is within risk profile) (d) Substantial public interest (insurance purposes, prevention of crime) |
(a) Regulators
(b) Insurers/Reinsurers (c) Anti-fraud databases, sanctions lists, court judgments and other databases (d) Credit reference agencies (e) Insurance intermediaries (f) Insurance broking platform administrators/advisers |
| Policy administration | ||
| (a) General servicing of the client account, including communication with you and sending you updates
(b) To update our records and maintain your policies with us (c) Collection and payment of premiums |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us and to keep our records updated) |
(a) Insurers/Reinsurers
(b) Banks (c) Insurance intermediaries (d) Debt recovery providers (e) Premium finance providers |
| Relationship management | ||
| (a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to study how customers use our products/services) |
|
| Claims Processing | ||
| (a) Managing insurance claims
(b) Defending or prosecuting legal claims (c) Investigating and prosecuting fraud |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to establish, prosecute, and defend legal claims, to assist client in assessing and making claims, and to assist with the detection and prevention of fraud) (c) Substantial public interest (insurance purposes) |
(a) Claims handlers
(b) Insurers/Reinsurers (c) Loss adjusters (d) Lawyers (e) Experts (f) Third party administrators (g) Law enforcement agencies (h) Anti-fraud agencies (i) Other parties involved in investigations or prosecutions |
| Renewals | ||
| (a) Contacting our clients to renew the insurance policy
(b) To evaluate the risks to be covered and premium calculation |
(a) Performance of a contract with you
(b) Legitimate interest (to assist client in assessing and making claims, and to assist with the detection and prevention of fraud) |
(a) Insurers/Reinsurers
(b) Insurance intermediaries |
| Throughout the contract | ||
| (a) Risk modelling
(b) Complying with our regulatory and legal obligations (c) Reviewing claims (d) Investigating fraud and preventing financial crime (e) Transferring books of business, company sales & reorganisations |
a) Performance of a contract with you
(b) Legitimate interest (to assist with the detection and prevention of fraud) |
(a) Insurers/Reinsurers
(b) Courts and lawyers (c) Auditors (d) Regulators (e) Legal enforcement agencies |
| Business and website activities | ||
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
(a) IT service providers |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) | (a) IT service providers
(b) Third party contractors involved in marketing/market research for us. |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
International Transfers
We do not transfer your personal data outside the UK.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you’d like to learn more about your rights, please see the website of the Information Commissioner’s Office.
You generally have the following rights, which you can usually exercise free of charge:
- Request access to your personal data.
- Request correction of your personal data.
- Request, in certain circumstances the erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request, in certain circumstances, personal data in an accessible and machine-readable format.
- Right not to be subject to decisions without human involvement.
If you have provided us with a consent to use your personal data, you have a right to withdraw that consent easily at any time. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.
If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above or have any other queries or concerns, please don’t hesitate to contact us at henry@assured.co.uk
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.