Getting protected should be a straightforward and pleasant process, and we want to make sure we protect your privacy along the way. So do take a few minutes to read this privacy and data policy; it explains what we do with your data, how we collect and use your browsing information and how we may use it for future marketing purposes. In a safe, secure and compliant way.
2. About Protect My Income
Protect My Income is an Appointed Representative of UK & Ireland Limited who are authorised and regulated by the Financial Conduct Authority. In respect of your data, Protect My Income is the data controller and responsible for the personal information it holds about you for sales, administration of policies and for any marketing purposes.
We take the privacy and security of your personal information seriously, so you can rest assured that your information will be properly managed and protected by us. Please read this notice carefully as it explains how Protect My Income and/or carefully selected third parties we work with collect and use your personal information.
You can ask for further information about the use of your personal information or if you need to raise a complaint, by contacting the Data Protection Officer with the details below.
Data Protection Officer
Protect My Income
3.What kinds of personal information we hold about you
We may collect and process the following:
• Information about you – for example name, age, gender, date of birth, nationality. We need this information to help us identify you, but also to allow us to contact you at the right time – such as when your policy needs to be reviewed or you are approaching the end of your policy term
• Contact information – for example email, address, postcode and phone numbers
• Online information – for example cookies and IP address (your computer’s internet address), if you use our websites
• Financial information – for example salary to help us determine the right type of product to advise you on
• Audio recordings – for example voice recording when you contact us. Calls are recorded for monitoring purposes to help us monitor the quality of the advice you are given, continually improve our service and also to protect you and your information
• Contractual information – for example details about your products and benefits
• Family & beneficiaries information – for example marital status, next of kin or nominated beneficiaries.
• Health information such as smoker status or medical-related issues relevant to your policy
• Information relevant to other products we have which may be of interest to you, for example date of your home insurance renewal or if you have pets or not
4. How we use your information
Any information supplied to Protect My Income is used to provide advice and/or recommendations for protection insurance products such as Life Insurance or Income Protection. The protection policies provided are administered by Protect My Income, and we will be handling the personal information you provide.
This includes any sensitive personal data such as health information which you provide as part of the application process. Where a joint application is completed, Protect my Income and your chosen insurer will sometimes send application updates to the contact information you provide, this will include updates about both applicants. Where we collect and process health information, we may ask each insured person to authorise a healthcare provider to supply relevant supporting information, including, where relevant, health information about their family or personal history.
Protect my Income may use personal information for the following purposes:
– Provide you with a quotation and a recommendation based on your needs;
– Apply for and set up your plan;
– Administer your plan;
– Review your cover;
– Claims handling;
– For the prevention, detection and investigation of financial crime, including fraud;
– To verify your identity, in accordance with the money laundering regulations;
– Statistical and analytical research;
– Where necessary, to comply with legal and regulatory obligations.
We may also use your personal information for marketing purposes, but only if you have provided the relevant consent and you would still hold the right to opt out at any time. See section 5 for more information on that.
We will use your information for the purposes listed above. For any other purpose, where appropriate and required, we’ll contact you to ask for your permission.
5. Who we may share your information with
• UK & Ireland Limited and appointed representatives.
• Insurance companies, to provide you with the appropriate protection advice and cover.
These include: Cirencester, MetLife, Hive, Exeter, Shepherds Friendly, British Friendly Society, Legal & General and Payment Shield.
• Other organisations in order to prevent, detect or investigate financial crime or fraud;
• Approved and appointed service providers, including those used to administer policies;
• Credit reference agencies;
• Relevant legal and regulatory authorities;
• Selected partners for the provision of incentives and rewards, such as vouchers, movies and meals, and other reward schemes;
6. The legal grounds we rely on to process your information
The legal grounds on which we rely are:
• to fulfil our contractual obligations (for example in order to provide the products or services you have requested and to contact you if a problem arises with them);
• your consent
• to pursue our legitimate interests
• to fulfil a legal obligation
We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of “legitimate interests” as a justification for processing your personal information. For example:
• To communicate with you about our services. We need to keep you informed about your use of our services for example sending you a confirmation email of your quotes or sending you reminders based on the information you have provided to us, such as when your insurance might need to be reviewed or updated.
• To personalise and improve our services for example, we may use your personal information to personalise aspects of our service
• For market research and analysis. This helps us to regularly review and improve the products and services we or our partners provide. Where possible data that we use/provide in this way will be in an anonymised format.
7. Controlling your marketing preferences
When you submit details for a protection insurance quotation through our website, through 3rd parties or other websites affiliated with Protect My Income, you will be asked if you’d like to opt-in or opt-out of receiving future marketing communications from Protect My Income and any of our carefully selected partners. This is recorded on our customer database.
We will only send marketing communications to you via the preferences you’ve chosen and regularly make the appropriate checks to ensure that we abide by those rules and only send communications to those who’ve requested as such.
Methods of communication for marketing will typically be (but not limited to); phone, email, text message, post.
During your protection insurance journey, Protect My Income reserves the right to use any of the above communication methods to get in contact and service your enquiry, even to those who’ve opted out of marketing communications – for as long as is deemed appropriate, but not longer than 60 days.
8. Information provided on another person
If you are submitting personal information about another person, then you confirm that you have their consent to provide such information and for their information to be used as set out in this notice, and that you have provided a copy of this notice to that other person.
9. Cookies and other uses of your online browsing data
When you visit one of our websites, we may collect information from you such as, your email address, IP address and other online identifiers. This helps us to track unique visits and monitor patterns of website traffic, such as who visits and why they visit.
The cookies and pixel tags information is then channelled through various 3rd party web applications. Examples of the software Protect My Income use are;
• Google Analytics; to help us monitor website traffic and view page-by-page behaviour. It also allows us to understand which browser type, or operating system visitors are using as well as which referring sites traffic has come from.
• Typeform; software which provides contact form data capture.
• We may choose to send carefully planned automated marketing emails or SMS messages, based on the insights learnt from your previous website browsing behaviour via our in-house customer records management system, our SMS system – Messagebird, or via our email marketing platform – Mailchimp. You can opt out of marketing emails & text messages at any time by contacting us on firstname.lastname@example.org. More information is available in section 5.
• We may choose to follow up with ‘remarketing’ activity; banner and text adverts placed automatically on 3rd party websites and on social media. These are controlled through services such as Google AdWords, or Facebook Business Manager.
You have the right to disable cookies on your browser and install 3rd party plug-ins to prevent behavioural ad targeting. Links below are provided for your reference.
The internet industry body, the Internet Advertising Bureau, has created a website which provides detailed information and advice on cookies and pixel tags https://www.iab.com/guidelines.
For more on behavioural advertising visit – http://www.youronlinechoices.com/uk/.
Another source about how to delete and control cookies is http://www.aboutcookies.org/.
At any stage, you can always contact us using the details above for any more information or help.
10. Transfer of personal information to other countries:
Your personal information may be processed in countries outside of the European Union (EU). Where we transfer your personal data to countries that are outside of the EU we will ensure that the transfer is carried out in a compliant manner and appropriate safeguards are in place and in accordance with the relevant data protection requirements.
11. Retaining your personal information:
We will retain and process your personal information for as long as necessary to meet the purposes outlined in this notice provided to you. We’ll keep your personal information in accordance with our internal retention policies. We’ll determine the length of time we keep it for based on the minimum retention periods required by law or regulation.
12. Your Rights:
You have the right to request access to your personal information, to have it corrected, erased, apply restriction and/or object to processing. If you request that your information be erased, we will comply with the request where it doesn’t conflict with any legal or regulatory obligations that we have. Where we are unable to delete your information, the data is marked as dormant and not processed for any reason other than to provide information if requested by the FCA relating to any investigations they may undertake.
If we are processing your personal information with your consent, you have the right to withdraw your consent at any time. This may mean however, that Protect My Income may not be able to provide you with the goods and services you requested.
For the purpose of providing you with a contract of insurance, your personal information may be processed by means of automated decision making and profiling by the insurance companies that we place you with.
If you have provided your consent to receive marketing information, you have the right to opt-out at any time.
You have the right to request a copy of the personal information Protect My Income holds about you.
To make any of these requests, please contact the Data Protection Officer using the contact details above.
13. Making a complaint:
If we get something wrong, or you’re not happy with our services, we always welcome the chance to help and rectify it. You can contact the Data Protection Officer using the contact details provided above or email email@example.com.
You can also place a complaint with the Information Commissioners Office by contacting them at:
Information Commissioners Office
0303 123 1113 (local rate) or 01625 545 745 (national rate)