Assured Futures Privacy Notice – v2.0

This document explains how we use your personal data.

This privacy notice tells you what you can expect us to do with personal information we hold on you, what kinds of information we hold, how we receive it and who we receive it from. It also explains who else we may share your information with, and give you details about your data rights and how you may use them.

This privacy notice is updated from time to time, to reflect any changes in how we use and handle personal information. If we make any significant changes we will let you know.

This version of the privacy notice was published on the 23/10/2019.

In this version, we have reformatted our privacy notice to make it clearer and easier to navigate. This includes adding hyperlinks to allow you to jump easily to different sections of the document. We haven’t made any significant changes to the way we use your personal data since the previous version of our privacy notice was published.

  1. Who does this privacy notice relate to?

    1. This privacy notice relates to the following types of individuals, where we hold your personal information:

      1. Individuals who are customers, including prospective customers who have received an insurance quotation, former customers who have previously held an insurance policy with us, and customer representatives, for example those with power of attorney;
      2. Employees of our business/corporate customers, including prospective and former customers and customer representatives;
      3. Visitors to our websites;
      4. Individuals who contact us with a query, concern or complaint;
      5. Individuals named on our insurance policies, such as joint policy holders or beneficiaries;
      6. Individuals who request information from us or permit us to contact them for marketing purposes;
      7. Third parties who make a claim against, or are subject to a claim from one of our policyholders in relation to an accident or other insured event.
    2. There are types of individuals who this privacy notice does not relate to, for example our employees and sub-contractors (including prospective and former employees and sub-contractors), employees of our current, former or prospective business partners and service suppliers, and members of the press.

    3. If you are one of these individuals and would like further information on how we collect, use and store your data, please contact us. Our contact details are shown in the “how you can contact us” section of this notice.

  2. Providing your personal data to others

    1. Our partner service providers. We may disclose your data to our partner insurers, and other partner organisations that we work with.

    2. Our professional advisers. We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice and managing legal disputes.

    3. Where we provide your personal data to any third party. Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party.

    4. To comply with legal obligations. In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual.

  3. Transfers of your personal data outside of the European Economic Area

    1. Where your personal data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an "adequacy decision" with respect to the data protection laws of the country to which it is transferred, or (b) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.

  4. Retaining and deleting personal data

    1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. However, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, for our legitimate interests, or in order to protect your vital interests or the vital interests of another natural person. Details of our retention periods can be found in our Retention Policy a copy of which is freely available on request.

  5. Amendments

    1. We may update this policy from time to time by publishing a new version on our website.

    2. You should check this page occasionally to ensure you are happy with any changes to this policy.

    3. We may notify you of changes to this policy by email.

  6. Your rights

    1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

      1. ayour request not being found to be unfounded or excessive, in which case a charge may apply; and
      2. bthe supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address);
    2. We may withhold personal information that you request to the extent permitted by law.

    3. You may instruct us at any time not to process your personal information for marketing purposes.

    4. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

    5. The rights you have under data protection law are:

      1. athe right to access;
      2. bthe right to rectification;
      3. cthe right to erasure;
      4. dthe right to restrict processing;
      5. ethe right to object to processing;
      6. fthe right to data portability;
      7. gthe right to complain to a supervisory authority; and
      8. hthe right to withdraw consent.
    6. Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.

    7. Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.

    8. Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. We will analyse each request for erasure and we will agree if there is no legitimate reason to retain the data to the normal retention period, at which point we will instruct anonymization of the data.

    9. Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

    10. Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.

    11. Your right to object to direct marketing. You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.

    12. Your right to data portability. Where you have given us consent to process your personal data for the performance of a contract, you have a legal right to receive a copy of the personal data we hold about you. We will not be accepting Data Portability files from other third party companies/individuals. When a data request is made of us we will make available all applicable personal data to you in a .CSV file or alternative machine readable format agreed by us to be passed to the appropriate third party on your instruction. We will not however process your data in this way if we believe that it may pose a threat to the security of the data.

    13. Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.

    14. Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.

    15. Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with the Information Commisioner's Office (ICO) responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
      Information Commissioner's Office
      Wycliffe House
      Water Lane
      Wilmslow
      Cheshire
      SK9 5AF
      Tel: 0303 123 1113

    16. Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

    17. Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.

  7. Cookie Policy

    1. When someone visits our site we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone. We will not associate any data gathered from this site with any personally identifying information from any source. We will make it clear when we collect personal information and will explain what we intend to do with it.

      Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

      The table below explains the cookies we use and why:


      Lucky Orange

      Names: _global_lucky_opt_out, _lotr, _lo_rid, _lo_u, _lo_v, _lo_cid
      Purpose: Tracks customer's behaviour throughout the journey, however does not store any personally identifiable information.
      More Info: https://help.luckyorange.com/article/173-what-cookies-does-lucky-orange-set


      Google Analytics

      Names: _gid, _ga, _gat
      Purpose: These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
      More Info: Google's privacy and security overview


      Optimizely

      Purpose: Offers a range of website analytics services for A/B and multivariate testing purposes. Optimizely helps better understand how their website is used.
      Opt out: https://www.optimizely.com/legal/opt-out/


      Site Session

      Names: ASP.NET_SessionId, ctmPmi, ctm, ctmAsu
      Purpose: This cookie is essential for our online forms. This cookie is deleted when you close your browser.
      More Info: Microsoft’ overview of session IDs


      Introducer tracking cookie

      Purpose: This cookie is used to measure the source of some visitors.
      More Info: N/A


      Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

  8. Our details

    1. This website is owned and operated by Assured Futures Limited. Assured Futures is part of the A-Plan Insurance Group of Companies.

    2. We are registered in England and Wales under registration number 3040737, and our registered office is at 2 Des Roches Square Witney OX28 4LE, and we are registered by the Financial Conduct Authority under Firm Reference Number 310164.

    3. You can contact us:

      1. aby post, using the postal address given above;
      2. busing our website contact form;
      3. cby telephone, on the contact number published on our website from time to time; or
      4. dby email, using the email address published on our website from time to time.
  9. Data protection officer

    1. Our data protection officer's contact details are: Jonathan Cumpstey who can be contacted via email: jonathan.cumpstey@aplan.co.uk or telephone: 01993893311.