CUSTOMER PRIVACY NOTICE
At Konsileo we take the protection of customers’ data seriously. This Customer Privacy Notice explains how the information Konsileo Ltd (9569872) and Konsileo (Trading) Limited (10100499) collects about you will be used, who it will be shared it with, and your rights and how to exercise them.
Who is Konsileo?
Konsileo is a commercial insurance broker using data and technology to put people and customers first. Konsileo’s technology disrupts the traditional broking model in two ways.
Firstly, it addresses the operational challenges of regulatory compliance, data capture and duplication with an intuitive platform that gives brokers back more time to provide excellent service to clients.
Secondly, our technology underpins the creation of a community of modern brokers without hierarchy. Brokers who support each other, share expertise, and are rewarded for working together.
How will your personal data be collected and processed?
As an insurance broker, Konsileo will need to collect personal information for a variety of reasons.
Contact details such as name, address, telephone numbers, and email addresses, are used to communicate with you about your insurance requirements.
Konsileo will also collect information about you, your assets, and potential liabilities to assess your insurance requirements, to approach providers for quotations, to put insurance policies in force, and for the ongoing servicing of those policies. When needed, Konsileo may need to collect details to process payments from or to you, such as bank account or payment card information.
In the event of a claim, Konsileo may be required to obtain further personal information so that the matter can be properly considered. This could include information about other parties involved in an incident. Where you provide information about other individuals, such as employees or family members, you are responsible for drawing their attention to this notice.
Data protection legislation includes that we are only allowed to collect or use your personal information if the reason to do so meets certain conditions. The exact reason will vary depending on the specific circumstances. The legal bases that we rely on are:
- For the performance of a contract:Our agreement with you to arrange insurance policies means that we must continue to use personal information. This would include obtaining renewal terms, making changes to your policy, submitting claims or handling any premium adjustments or claims payments.
- Insurance:The Regulations make special provision for the processing of certain ‘special category data’, such as health or criminal conviction data, if the processing is necessary for an insurance purpose.
- To meet a legal obligation:We are required to perform certain checks on customers, such as to confirm their identity or ensure there are no reasons why we should not do business with them. We may also be obliged to provide information to a court or regulatory body.
- Legitimate interests:The law allows us to hold or use personal information if we have a legitimate reason to do so. For example, having arranged your insurance, we will keep records in case any claim or potential dispute arises in the future so that we can establish the circumstances and, where appropriate, defend our position. Also, we may use your contact details to promote our services. Where we rely on this basis, we will balance our interests with your own rights under data protection laws. For example, we will maintain a policy so that we do not keep information longer that is reasonable.
- Consent:If no other legal basis applies, we may rely on your consent to use your personal data, for example to send marketing materials to prospective customers.
We may also obtain personal information from other sources in relation to your insurance policies. Examples of this include previous and current insurers or brokers, loss adjustors, and loss assessors. We require all such parties to comply with data protection legislation.
Who will your information be shared with?
In the event of arranging your insurance, there are several situations where your personal information will be shared with other parties. These include:
- Where we obtain quotes, amend your policy, or make a claim we will forward information to product providers (insurers, managing agents or other intermediaries)
- Some product providers may appoint another party to administer the policy or respond to claims and complaints on their behalf
- Where you require us to apply to pay your premium in instalments, we will share relevant information with credit providers to obtain their terms
- Where we are required or permitted to do so by law or regulation, such as prevention of financial crime
- Where we provide services in partnership with another party
- With third party service parties unrelated to insurance, such as data hosting / storage providers, or technology suppliers
If we undergo a reorganisation, or if some (or all) of our business or assets change ownership, we may transfer your personal information to the successor company to ensure continuity of service.
Our agreements with third parties include requirements to comply with relevant data protection legislation so that your rights are maintained.
We will not send your personal information outside of the European Economic Area (EEA). However, some insurers may do so and will provide details in their own Privacy Notices.
How do we use automated decision-making?
In some circumstances we may need to process personal information using automated decision-making by, or at the direction of, product providers. This involves assessment of the information provided to determine whether a product is offered and under what terms.
Automated decision-making could limit the range of products available to you and if you disagree with the result, you have the right to request a manual assessment of the information provided. If you require a manual assessment, please contact us.
What if you apply for a job on our website?
On our website you may apply for a position in our organisation. If you decide to do this, then you will be required to submit your personal details including previous employment experience and qualifications. This information is used for the specific purpose of assessing your suitability for a position in our business and you will be required to consent to the use of your personal data for this purpose. If you do not consent to our processing your data for this purpose, then our ability to consider your application may be limited.
Our website may also have links to 3rd party websites. This Privacy Notice only applies to this website. You should therefore read the privacy policies of the other websites when you are using those sites.
What about the clients of Konsileo application customers?
As part of the service that we provide to our customers and clients, we are required to collect, process, or store the personal information of clients of our customers (e.g. policyholders). All this information is processed strictly in accordance with the instructions of our customers and is stored securely on servers located within the EEA.
For more information about cookies and how we use them, please read our cookies policy section.
How will we use your personal data for marketing purposes?
We will use your contact details to keep you up to date with industry developments and insurance products that may be appropriate for you through our newsletters. We will only send this where regulations permit us, or where we have your permission to do so.
At any time, you can request to no longer receive marketing communications, either by contacting us using the details below, or by ‘Unsubscribing’ using the link in any marketing email.
How do we retain your data?
There are several reasons why Konsileo will retain personal information, such as legal or statutory obligations, to process claims, or to respond to any complaint or dispute. We are sometimes contractually bound to retain information on behalf of product providers.
For most policies, we will retain records for up to seven years following expiry of the policy or termination of our services.
Some policies can be claimed against long after they have expired. We will retain records of these for longer than seven years based on the likelihood of any claim, complaint, or dispute arising.
Where we have obtained your consent to hold personal information, we will retain it for as long as we have your consent, subject to the above timescales.
How can you control your data?
Data regulations and legislation provide you with certain rights over the personal information we hold.
- You can request details of some, or all, of the personal information we hold about you. This is often referred to as a Subject Access request.
- Where you believe personal information is no longer required, you can request that it is deleted. However, we may not be able to do so if we still have a legitimate basis for keeping it, such as servicing your policy.
- If you believe that personal information we hold about you is incorrect, you can ask us to correct it.
- You can request a copy of your personal information to be provided in a portable (electronic) format. We will endeavour to meet such requirements where the format is reasonable and in common use.
- Even if you previously provided consent to receive marketing communications, you can withdraw your consent at any time.
In addition to these, you can ask us to restrict the use of your personal data if any of the above apply, but you do not wish us to delete it.
We aim to meet any requests promptly and as fully as possible. In some cases, we may be prevented from completing requests for legal reasons or due to conflicting legitimate interests. If this is the case, we will explain our reasons why.
There is no charge for requests of copies, amendments, or deletions of personal information. However, we reserve the right to charge an administration fee where requests are unreasonably frequent or excessive.
We recognise the importance of service and set ourselves high standards. Should there be an occasion when we do not meet your expectations we are equally committed to dealing with any complaint in a thorough and professional manner.
If you wish to register a complaint or request a copy of our complaints procedures, please contact us:
- In writing, addressed to Complaints at the address shown at the end of this document;
- By telephone to 020 7183 5562
- By email to firstname.lastname@example.org
If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service (FOS). You can find out more about this by visiting the FOS web site at www.financial-ombudsman.org.uk.
If you are a consumer and your complaint relates to insurance purchased from us via electronic means (e.g. on-line or via email or mobile phone) then you are also able to use the EC On-line Dispute Resolution (ODR) platform at http://ec.europa.eu/consumers/odr/ who will notify FOS on your behalf.
A copy of our procedures for dealing with complaints is available on request.
Changes to this policy
Version Date: 20 June 2018