This Privacy Notice explains when and why we collect personal information about you when you visit our website and app, how it is used, who we share it with and your rights as the data subject. We are the data controller for the purposes of the personal data we will collect. We do use other people to process some of your data and in some cases, the insurance partners we have will be considered the joint controller of your information.
INSHUR is a trading name of Inshur UK Limited, which is Authorised and Regulated by the Financial Conduct Authority under firm reference number 916800 to carry on insurance distribution activities. Inshur UK Limited is registered in England and Wales company number 10830222. Registered office at 2nd Floor, 1 Jubilee Street, Brighton, England, BN1 1GE.
In this Privacy Notice, references to “we” or “us” or “INSHUR” are to Inshur UK Limited. We are the Controllers of your personal data.
We reserve the right to amend this Privacy Notice at any time and without notice in response to changes in data protection laws and privacy legislation.
Who we collect personal information about
We collect and hold personal information about:
When we collect personal data
We collect personal information:
Uses for your data
The personal information that we collect will depend on your relationship with us. We will collect different information depending on whether you are a policyholder, named driver or other covered party or beneficiary under a policy, website/app user, claimant, witness, expert, representative or other third party.
Please note, in certain circumstances we may request and/or receive sensitive personal data about you. For example, we may need access to health records for the purposes of providing you with a policy or processing claims, or details of any unspent criminal convictions for the purposes of preventing, detecting and investigating fraud.
If you provide personal information to us about other individuals you agree: (a) to inform the individual about the content of this Privacy Notice; and (b) to obtain any consent where we indicate that it is required for the processing of that individual’s personal information in accordance with this Privacy Notice.
Please view the relevant section below for detailed information regarding the types of personal information we are likely to collect and use about you.
Sensitive personal data
How we collect your personal data
We collect personal information from a number of different sources including:
Purposes for which your personal data is used
We may process your information for a number of different purposes and under data protection laws we need a reason for doing so. We have set out below the reasons why we process your information and the applicable circumstances when we will process your personal information.
Our provision and administering of your insurance contract.
We may use your personal information for this purpose when:
The normal legal basis for processing customer information is for our own legitimate business purposes
In specific situations, we require your information to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests, This includes (but is not limited to):
*when you provide your details to us and subsequently do not choose to opt out from receiving our communications we will use your personal information, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centre about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable in the UK.
Note: In specific situations, we may also collect and process your data with your consent. For example, when you tick a box or sign up to receive email newsletters.
Sometimes we have a legal or regulatory obligation to use your personal information
We may use your personal information for this purpose when:
Occasionally we need to use your information to establish, exercise or defend our legal rights
We may use your personal information for this purpose when we are faced with any legal claims and/or We want to pursue any legal claims ourselves.
Sometimes we need to use your personal information for reasons of substantial public interest
We may use your personal information including sensitive personal data such as that relate to criminal convictions for this purpose when investigating fraudulent claims, carrying out fraud, credit and anti-money laundering checks.
Criminal conviction sensitive personal data
Data Protection Legislation allows for the processing of criminal conviction sensitive personal data for an insurance purpose, this includes the processing of such data for advising on, arranging, underwriting or administering of an insurance contract and administering a claim under an insurance contract.
Who we share personal information with
From time to time, we may share your personal information with the other companies in our group and with third parties. We will keep your personal information confidential and only share it with the third parties listed below for the purposes explained previously.
We have trusted relationships with these carefully selected third parties and all third parties are bound by contract to maintain the security of your personal information and to use it only as permitted by us. If you would like further information regarding the disclosures of your personal information, please see below for our contact details.
Disclosures within our group
In order to provide our services your personal information is shared with other companies in the INSHUR Group. Your personal information might be shared for our general business administration purposes or for the prevention and detection of fraud.
Disclosures to third parties
We also disclose your information to the third parties listed below for the purposes described in this Privacy Notice. This might include:
We may also disclose your personal information to other third parties where the disclosure is required by law or by a regulator with authority over us or you, such as where there is a court order, statutory obligation or FCA request; and we believe that such disclosure is necessary in order to assist in the prevention or detection of any criminal action (including fraud) or is otherwise in the overriding public interest
Our approach to sending data outside of the UK and European Economic Area (EEA)
Personal information that we collect may be shared with an organisation located outside of the UK and EEA. It may also be processed by us or by one of our suppliers outside of the UK and EEA. When these circumstances apply, we will always take measures to ensure your data is protected.
Any requests from organisations such as law enforcement or regulators will be reviewed and validated prior to disclosing data with the exception of a legal or regulatory requirement, your data will only be transferred outside of the UK and EEA when we are satisfied the country is recognised as having an adequate level of data protection or there is another arrangement in place to offer protection of your data.
Automated decision making
We may use Automated Decision Making (ADM) based on the personal information you provide to assess whether you meet the underwriting criteria for the insurance product you have selected.
We may also use automated decision making:
You have the right to contest any decision produced by a solely automated means and request for human intervention. If you do this we must allow you to express your point of view, to obtain an explanation of how we reached the decision, and allow you to challenge the decision. To do this, please contact our Data Protection team at [email protected] or using the address in the ‘Our Contact details’ section.
We may use your personal information to provide you with information about our products or services which may be of interest to you. We rely on our legitimate interests (to develop our products and grow our business) to send you marketing communications in line with the GDPR and Privacy and Electronic Communications Regulations (PECR).
You can always update your marketing preferences at any time by contacting our customer services team on [email protected] or by telephone. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary.
How long we keep personal information
We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice and in order to comply with our legal and regulatory obligations.
In most cases your personal data will be retained for six years.
However, it may sometimes be necessary to retain data for longer, for example where there are legal grounds for doing so, or in the event of a claim or a potential claim under a policy. Even if we delete your personal information it may persist on backup or archival media for legal, tax or regulatory purposes.
You have a number of rights which are outlined below. If you wish to exercise these rights, please contact our Data Protection team at [email protected] or using the address in the ‘Our Contact details’ section. In most cases, we will complete your request within 30 days.
The right to access your personal information – You are entitled to a copy of the personal information we hold about you and an explanation of how we use it.
The right to rectification – If you believe that any information we hold about you is incorrect or incomplete you can contact us to ask us to update or amend it.
The right to erasure – In certain circumstances, you can ask us to delete your personal data. This right is not absolute – we may be required to keep it for legal or regulatory reasons.
The right to restriction of processing – In certain circumstances, you can ask us to stop using your personal information, for example if you believe the personal information we hold about you is wrong.
The right to data portability – In certain circumstances, you can ask us to transfer your personal information to another organisation.
The right to object to processing – You have the right to object to us processing your personal information where we rely on a genuine business need to process that personal information. In some circumstances we won’t be able to stop processing your information, but we will let you know if this is the case.
Rights relating to automated decisions – If you have been subjected to an automated decision and do not agree with the outcome, you can ask us to review it.
The right to lodge a complaint with the ICO – You have a right to submit a complaint to the Information Commissioner if you believe we have not complied with our obligations under relevant data protection laws and/or regulation:
How we protect your information
We use a range of organisational and technical security measures to protect your information.
Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We restrict access to your information as appropriate within INSHUR to those who need to know that information for the purposes set out above.
Firewalls are used to block unauthorised traffic to the servers and the actual servers are located in a secure location which can only be accessed by authorised personnel. Our internal procedures cover the storage, access and disclosure of your information.
We cannot be held responsible for the privacy policies and practices of other websites potentially linked to our website.
We do take great care in ensuring only links to companies, organisations and individuals following the same standards and policies as us remain on our website, but we cannot guarantee this. In such instances, you are advised to check the privacy policies on external websites that are not a part of INSHUR.
Our contact details
If you have any questions about how we collect, store or use your personal information, you may contact our data protection team at:
Data Protection Team
2nd Floor, 1 Jubilee Street,
Brighton, BN1 1GE
Email: [email protected]
Changes to our Privacy Notice
We keep our Privacy Notice under review and reserve the right to make changes to our Privacy Notice in accordance with UK legislation.
We recommend that you make regular checks on our Privacy Notice to ensure that you are aware of any changes that may have been made.
This Privacy Notice was last updated on 1st October 2022.