Freedom Privacy

Our website is operated by Freedom Insurance Services Ltd, a limited company registered in England under company number 4399749, whose registered address is: 58 Market Square, St Neots, Cambridgeshire, PE19 2AA.

We are authorised and regulated by the Financial Conduct Authority, reference number 306536.

If you would like further information on how we collect, use and store your data, please contact our Data Protection Officer, Roland Gilliam, by email: roland.gilliam@freedominsure.co.uk or in writing: Data Protection Officer, 58 Market Square, St. Neots, Cambridgeshire, PE19 2AA.

We collect data to operate effectively and provide you with the best and fairest service with our products. You would provide some of this data directly, such as when you fill in your details on our system to get a quote. We get some data by recording how you interact with our website, for example, using technologies like cookies.

We also obtain data from third parties. These vary over time but current examples include:

• We use a live chat provided by Click 4 Assistance, a 3^rd party UK based software company. Information regarding how the data is processed and stored can be viewed at: https://www.click4assistance.co.uk/click4assistance-web-chat-software-cookie-policy
• We use Google’s analytical services to help improve and develop our website and for operational business.
• Publicly available sources such as open government databases or other data in the public domain.
• Choosing to leave feedback with us via Feefo means that you provide them with your name, email address, policy number and date on which your policy with us was purchased.
• Firemelon, our website developers, will create backups for your data for business continuity reasons in line with our retention periods and in some cases have administrative access to some data in line with them provide us with their services.

You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose to not provide data that is necessary for us to offer you our products or services, you may not be able to obtain our products or use our services.

The data we collect can include the following:

Name and contact data

We initially collect your date of birth as age is a factor in our pricing structures and your postcode so that we can create a quote record for you that can only be accessed by three pieces of information for data protection.

We would later take first and last name, email address, postal address, phone number and similar contact data if you decide to take a policy out with us. This allows us to provide you with policy documentation and is required for the insurance contract you would have with us.

Health data

We will be collecting any sensitive health data where needed to help us provide a fair service and an equitable premium to you where possible.

Payment data

We collect data necessary to process your payment if you make a purchase with us. This payment data is collect by a third-party payment provider (pay360) via a secure portal.

We also collect information that you provide to us and the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide for customer support. When you contact us, such as for customer support, phone conversations and chat sessions with our representatives may be monitored and recorded.

Use of your personal information

Freedom Insurance Services Ltd uses the data we collect for several reasons, described in more detail below:

• We will collect data, including personal information and risk details, solely to enable us to obtain and provide insurance quotations, arrange and administer your insurance. Data collected by us is contractual, and for our legitimate business interests as an insurance intermediary.
• To send communications, including promotional communications.

Providing our Products

We use data to provide and improve the products that we offer and perform essential business operations. This includes operating the products, maintaining and improving the performance of our services, developing new online features and providing customer support. Examples of such uses include the following:

• Providing the products: We use data to carry out your transactions with us and to provide our products to you. These products are based on data individual to you that you provide to us.
• Customer support: We use data to find and correct issues with our systems and online services, as well as addressing your policy questions. We also provide customer care and support services online via our Live Chat feature or via email or telephone contact.
• Product improvement: We are in frequent contact with both our underwriters and third parties to improve our products. For example, we are in contact with Verisk to alert them to potential improvements to the medical questions.
• Security, safety and dispute resolution: We use data to protect the security of our clients, to detect and prevent fraud and to resolve disputes. For example, we would reference data for necessary data protection checks, we also reference data against the government’s Financial Sanctions Targets list.
• Business Operations: We use data to develop analysis and performance objectives that enable us to operate, protect, make informed decisions and report on the performance of our business.
• Client feedback: If you purchase a policy with us, we invite you to provide us with feedback via Feefo, a third-party client feedback service. We would also use data provided by you via email or telephone to respond to your feedback.

Where we can, we do not use any data where clients might be identified whilst performing the functions listed above.

Communications

We use data we collect to communicate with you and to personalise our communications with you. For example, we confirm any quote given or policy purchased with correspondence confirming the quote or policy details, this correspondence will include your contact details as well as any provided health data.

Additionally, you can be provided an optional link to provide us with feedback and as a policyholder, we can add you to our marketing list so that we can provide you with communications about our product and services where you have a legitimate interest. You will be given the opportunity to opt-out in all marketing communications.

If, at any time in the future, we wish to use your personal data in ways other than those set out in this privacy notice, then we will notify you about this and seek your permission to do so.

Substantial public interest

The Data Protection Bill lists insurance as being a valid reason to process sensitive data under the definition of a substantial public interest.

We share your personal and health data with our insurer, as necessary, to provide any product you have requested or authorised, and to complete any transaction that occurs as a result. We share data with third party companies and service providers when required by law or to respond to legal processes, to protect our customers, to maintain the security of your data and our products.

Data outside of the EU

There are some situations where data collected by us would need to be sent outside of the EU, such as in the following examples:

• If you are abroad outside the EU and need medical assistance, we may be required to provide the local medical assistance office with your data to help this process. This communication would be sent securely.
• Our underwriters & developers may store data on servers located outside of the EU.

All selected companies may have access to personal information if needed to perform such functions, but will only be permitted by us to use such personal information for performing that function and not for any other purpose.

In all cases, any use of your personal information by Freedom Insurance will comply with this privacy policy.

Whilst we make every effort only to tie-in with reputable companies who have a similar high regard for your privacy, you should make sure you are aware of what their privacy policies say, as we are not responsible for the policies and practices of other companies.

If, in the future, a third party acquires Freedom Insurance or its assets (whether by merger, acquisition, reorganisation or otherwise) customer data, including personal information, may well be one of the transferred assets.

The internet is not a secure medium and Freedom Insurance cannot absolutely guarantee the security of your personal information provided over the internet. However, we have put in place various security measures as set out below.

The Freedom Insurance website and associated databases are protected by certified firewalls in order to protect your personal information from access by unauthorised persons and against unlawful processing. The website uses the latest technology with full backups. We also keep your personal information confidential. All outgoing and incoming emails are scanned for viruses.

Data Retention

We also keep your personal information confidential. If you decide to take a policy out with us, your details will be kept on our system for 6 years for the purposes of administration, claims and complaints handling. If we give you a quote only, your details will be held on our system for 1 year before being completely anonymised.

Quote and policies done through our website will be stored for 1 year so you can access your details from our website.

Any emails you send us will be kept only for as long as they are needed. Specific text from your emails may be added to your record which means they will then be kept in that form for 6 years/1 year as appropriate.

If you decide to contact us via telephone, the calls are automatically recorded for compliance and legal reasons, they are held for 6 years. Any chats via Click 4 Assistance will be kept for 6 years.

For internet based advertising, we retain your data until you decide to opt out, at which point you will be deleted from our marketing list. All our marketing material will provide a link and option to opt out of further marketing.

Client feedback given via Feefo on our website will be kept forever. Feefo does not allow reviews to be deleted or altered as it prides itself on the honest picture its reviews provide.

Your rights

We draw your attention to the fact that as a data subject, you have the following rights under the General Data Protection Regulation (GDPR), which this policy and our use of personal data have been designed to uphold:

• The right to be informed about our collection and use of personal data
• The right of access to the personal data we hold about you. If you would like a copy of some or all your personal information, please contact the Data Protection Officer via the methods listed under the INFORMATION ABOUT US section of this policy.
• The right to rectification. If any personal data we hold about you is incorrect or inaccurate, please contact us using the details under the CONTACT US section.
• The right to be forgotten.  We hold your data for no longer than we need to, which is detailed under the Data Retention section just above. If you would like us to delete your details earlier, please contact us using the methods listed under the INFORMATION ABOUT US section of this policy. Please note: there may be circumstances where we will be unable to delete your records earlier.
• The right to restrict the processing of your personal data.
• The right to data portability.
• The right to object to using your personal data for particular purposes.
• Rights with respect to automated decision making and profiling.

If you have any cause of complaint about our use of your personal data, please contact us using the methods listed under the INFORMATION ABOUT US section of this policy and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the Information Commissioner’s Office.

Via Telephone: 0303 123 1113

Via Online Form: https://ico.org.uk/concerns/

If you have any cause of complaint about our use of your personal data, please contact us using the methods listed at the top of this page and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the Information Commissioner’s Office. Via Telephone: 0303 123 1113 or via Online Form: https://ico.org.uk/concerns/

We keep our privacy policy under constant review and we will update this web page routinely, we suggest you check this page periodically.

Links

Our website does contain links to other websites. This privacy policy only applies to our website so if you are directed to another website, you should familiarise yourself with their website privacy policy.

If you have any questions, concerns, comments or complaints about this privacy policy and/or our collection or use of personal information, or if you wish us to stop processing your personal information for any purpose or purposes, then please contact us via the details below:

Freedom Insurance Services Ltd, 58 Market Square, St Neots, Cambridgeshire, PE19 2AA, UK
operations@freedominsure.co.uk | Tel: 01223 446 914