We use your information in several different ways, for different reasons — what we do with it, depends on the type of information that you provide to us and the reason why we need to ask for it. If you provide personal information about someone else (other person), for example when a joint enquiry or application is made, or if you're an individual or employee of a related or partner company that we have entered into an agreement with and you are making a referral you must do so with the permission of the other person.

If you are a third-party organisation with clients who are interested in receiving services and or relevant products from us and you wish to introduce these clients to us with the permission of the client and so their needs can be fulfilled, you will need to enter into a referral partner agreement with ourselves. To do this and if you choose to give us your name, company name, telephone and/or email contact details, plus any other information relating to your business, we’ll use your name and contact details to contact you, help you with your enquiry and start the process for you to become a referral partner.  It’s the same whether you call us directly or fill in a form on our website, we are using these details at your request, to contact you as a first step prior to the possibility of entering into a contract or agreement with you.

If you become a referral partner you must only pass on the other persons details, subject to the terms and conditions of any agreement that has been put in place to ensure we both comply with our respective obligations under the data protection legislation in respect of the personal data that we are processing pursuant to or in connection with the performance of our agreement.

If you enter into a policy jointly with another person your personal information and any information about the service provided to you may be shared with the other person. The personal information about the other person will be used in the ways as described in this privacy notice.

You don’t have to give us any of your personal information, but if we are collecting your data to provide our services to you and it’s necessary to enter into a contract, we will be unable to provide our services if you choose not to provide your information.

• If you visit a third-party associate's website or communicate with a third-party and make an enquiry or asked to be referred for advice or a quote and you give your name, date of birth and telephone and/or email contact details, the third-party will explain that an FCA authorised broker will contact you – and they’ll introduce you to us by passing on your details to us. We’ll use your name, contact details and date of birth to contact you, help you with your enquiry and start the process of getting you a quote. It’s the same if you call us directly or fill in a form on our website, we are using these details at your request, to contact you as a first step prior to the possibility of entering into a contract with you.
• To provide you with a quote, and a recommendation we’ll ask you a few questions about your personal and financial circumstances. We’ve got to do this to give you what you have asked for and before we enter into a contract with you. We are also obligated to meet high standards that are expected of us as a broker that provides an advised service and one who is authorised and regulated by the Financial Conduct Authority (FCA). To provide our services, we must ask you questions to take into consideration your individual needs before we can provide a recommendation to you.
• To complete an application for insurance, it is necessary to ask a few more questions about you, or your business in relation to business protection insurance and your property for home insurance.  We will pass your answers securely to an insurance provider to put arrangements in place and to fulfil our contract with you. If you are applying for life insurance, critical illness cover or income/business protection, some of the questions we ask relate to your physical or mental health, for example existing medical conditions, family or personal history in relation to some conditions. We ask for this information for insurance purposes and we need the information to arrange underwriting, so the provider can administer your policy and deal with claims. We request this personal information that’s related to risk factors in our own and the insurance providers legitimate interests, to maintain standard industry practice and allow the availability of insurance at a fair and reasonable cost through risk-based pricing. This essentially makes it fairer for everyone.
• If you purchase a policy, we’ll take payment information from you, but don’t worry, we do not keep this information. We need these details, so we can complete your contract and finalise your policy arrangements and we pass the information securely to your policy provider to process the sale.
• To perform our contractual duties and give you great customer service and support we’ll use your contact details to send you (by letter, email, telephone or any other appropriate means) routine service messages and provide you with any information you need, or we’re required to give you, in relation to any policies you enquire about/and or purchase.
• Furthermore, to provide our customers with a high level of service and to give you the very best support we can, we may collect and store other types of personal data from you, such as your next of kin or death beneficiary information. Whilst this information is that of a third-party, not your own personal data, we do this in both our, the insurance providers and your legitimate interests to be able to assist in the event of a claim following the death of a policyholder.
• When you provide us certain personal information such as your name, date of birth, address, postcode, and other contact details we may use this information to send you personalised offers, quotes or to be able to introduce you to or provide you with insurance and/or associated financial services in the future. We think that if you express an interest in or use our services once and we serve you well, you might want to use our services again in the future and you might reasonably expect to receive quotes and hear about similar or associated products and services that we or third-parties we have partnered with offer that may be of interest to you. We do this in our own legitimate interest to promote a range of products and services and maintain a long-term relationship with you. We’ll specifically ask when we speak to you in person for the first time if you would mind us using your name, email address or phone number to keep you up to date about similar or associated products and services. If you would prefer us not to contact you for this reason, you can tell us at any time and we won’t bother you with marketing messages in the future. Or you can unsubscribe using the link within any messages you receive.
• All telephone calls, to and from our business are recorded. The only part of our conversation that is not recorded is credit or debit card details, we do not record or keep cardholder data to prevent payment card data loss. Calls are recorded because as an FCA authorised broker, we are legally obligated, and it’s in our own and the insurance providers legitimate interests, to keep an accurate record of our business transactions and so that they can be used for quality audits and risk assessment or evaluation and investigation; to ensure that we are acting in your best interests, providing correct advice, you are being treated fairly and that insurance providers and the regulator (FCA) know that products are being sold appropriately and that rules and/or codes of conduct are being followed. Call recordings are necessary for insurance purposes to help resolve matters in the event of queries, complaints or claim disputes and to help assist with the prevention, investigation of and detection of fraud, dishonesty or other unlawful acts – protecting the interests of the public and honest customers.
• If, during the course of progressing your enquiry, it becomes apparent that a related, or partner company that we have a commercial agreement/contract with, may be better placed to deliver services to you, in your interests, our own and those of the third-parties legitimate interests, to promote their products (for example; private medical/health insurance, accident sickness and unemployment cover, retirement income or estate or funeral planning, equity release, mortgages or pensions), we will make an introduction. We do this by sharing your personal details such as your name, date of birth and contact details, as well as any other relevant information you have provided such as your employment, relationship, residential, dependent status and income/salary, rent/mortgage details. We think you might reasonably expect us to do this in our further interests and desire to provide you with a good service and to deliver good customer outcomes, but we won’t make the introduction if you don’t want us to.
• As part of our ongoing service and commitment to our customers, we periodically offer a review service and if, during the course of progressing your review, it becomes apparent that an associated company that specialises in private medical/health insurance, accident sickness and unemployment cover, retirement income or estate or funeral planning, equity release, mortgages or pensions may be well placed to deliver services to you, in our legitimate interests to provide you with the best possible ongoing customer service and to promote the services of partner companies that we have entered into a commercial agreement with, we will make an introduction and pass on any relevant personal information to the appropriate third party. We think you might reasonably expect us to do this in our interests to further our business and desire to provide you with a good service and to deliver good customer outcomes, but we won't make the introduction if you don't want us to.
• To prevent and detect fraud and protect you against unauthorised or unlawful access to your personal data we will use your personal information to verify your identity and in other instances where we have a legal or regulatory obligation to do so, for example, to adhere to anti-money laundering regulations and our data protection commitments.
• If you, a regulator or another authority makes a complaint about us, we will use your personal information to investigate, assess and resolve the complaint. It is in our own and the insurance providers interests to handle complaints competently and we are contractually and legally obligated to deal with customer complaints appropriately.
• We strive to put our customers first and at the heart of everything we do, so as you might reasonably expect, finding out whether you are satisfied with the level of service we provide, and whether we’re achieving the right outcomes for our customers is very important to us. That’s why we use your contact details, provided to us during the process of providing our services to you, to gather feedback from you post-purchase. We may use third-party independent specialists to survey or research your opinion and collect reviews from our customers in our own legitimate interests and so we have quality management information and reports that provide comprehensive and balanced insight to help us identify problems and get the information we need to help us to improve our services.
• Your personal information is also further used for statistical analysis purposes. For example, we will report back to a third-party ‘introducer’ to whether you took out a policy or not if your original enquiry came through a third party. Or we will share management reports and forecasting internally and with policy providers for whom we are acting as an intermediary. We do this to help develop our business, assess our performance and plan for the future.

We do not, and will not, sell any of your personal data to any third party. We believe that this is essential to maintaining our relationship with you. However, we do pass your personal information securely to the following categories of companies, as an essential part of being able to provide our services to you:

• Insurance companies, intermediaries, and re-insurers – we are an intermediary and we can help you make arrangements, but your policy will be put in place with a leading policy provider.
• Insurance quote providers and policy comparison software providers – to provide you with a quotation and in some circumstances to make comparisons of plans based on their statistical likelihood of matching your needs or meeting a claim, we will share your information with insurance companies or use a third-party software to obtain real-time pricing and comparative quotes from a range of leading UK insurance providers or to provide detailed knowledge about historical and current critical illness policies.
• Quality assurance auditors – companies who provide professional services to make sure we are complying with the rules of our regulator, the FCA, and independently provide assessment of our competence.
• Data validation and communication providers – companies who validate contact details and manage our phone systems and the distribution of post, email and text messages who need access to your personal information to provide elements of our service.
• IT service providers – we use developers who provide technology platforms, systems or other IT services that may have access to your personal information. However, we have strict access controls in place and only those contractors that need access to your data to provide their services will be authorised.
• Related and associated or referral partner companies – if your enquiry comes to us as a referral or via a third-party ‘introducer’ or a related company, or if your enquiry leads us to make an introduction to a related, associated company or specialist company that we have partnered with, there will be an exchange of your personal information in the first instance and subsequent reports to whether you do, or do not, take out a particular product or policy, for administrative, management forecasting and planning and statistical purposes.
• Regulators and authorities – upon their request and as we may be required to do so either by law or during investigation of a complaint.
• Law enforcement and fraud prevention agencies – we will share your data when we are required to do so under a legal or regulatory obligation or court order, so we can help tackle fraud.
• Feedback, opinion, and review specialists – we will share your contact details with customer satisfaction researchers, opinion/survey companies or Feefo, so they can independently gather feedback from you about our services.

If the company receiving your personal information is processing the data to provide elements of our service for us, such as data validation, quote providers and policy comparison and other software providers, quality assurance auditors, customer satisfaction researchers, opinion/survey companies or Feefo the independent feedback platform, we have a contract in place with them to ensure that they cannot do anything with your personal information, unless we instruct them to. They will not share your personal information with any other organisation without our authorisation, they will hold it securely and they must comply with their data protection obligations.

We do not routinely transfer your personal information outside of the UK or European Economic Area (EEA) where transfer of data is not restricted, and additional safeguards are not required to protect your data. However, a product or service may be administered from a country outside Europe. Any personal data received from companies transferring from the EEA must comply with EU data protection laws, and we will only transfer data outside of the EEA if the organisation receiving your personal data has provided adequate safeguards, we have an international data transfer agreement in place and your rights under the UK General Data Protection Regulation are enforceable.

We’ll hold on to your information for as long as is needed to be able to provide our services to you, and for at least as long as your policy is in force. Your personal information will also be held for as long as is necessary or required for insurance purposes and to comply with legal or regulatory requirements, resolve disputes, prevent fraud, dishonesty and abuse, or to handle complaints. For these reasons we’ll keep your information for accurate records and evidence that may be required to help resolve the problem, provide risk-related reporting and quality of service analysis.

We may even keep your information for a reasonable period of time after your policy or your relationship with us has ended. However, we do periodically review data that we hold to decide whether it is still necessary to keep your information, if your policy is no longer in place, has been cancelled, has expired or your information is no longer needed for us to provide the services to you.

In the absence of specific legal, regulatory, or contractual requirements but it’s necessary to keep your information for administrative, management forecasting and planning and statistical purposes, we will limit what we keep where possible to minimise risk and safeguard personal information.

You have a lot of rights relating to your personal information:

• The right to be informed about how we use your personal information (that’s why we have produced this notice)
• The right to ask for confirmation of and access to the personal information we hold about you
• The right to ask us to amend your information if it is inaccurate or incomplete
• The right to stop marketing emails or calls from us, which you can do by contacting us  at any time
• The right to request that we delete your information, or stop using it in some circumstances
• The right to complain to the data protection regulator in the UK, the Information Commissioner’s Office