Qdos Vantage Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.qdosvantage.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 or EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” Means Qdos Vantage Ltd, a limited company registered in England under company number 08850854, whose registered address is Windsor House, Troon Way Business Centre, Humberstone Lane, Thurmaston, Leicestershire, LE4 9HA.
2. Information About Us
2.1 Our Site is owned and operated by Qdos Vantage Ltd, a limited company registered in England under company number 08850854, whose registered address is Windsor House, Troon Way Business Centre, Humberstone Lane, Thurmaston, Leicestershire, LE4 9HA.
2.2 Any enquiries in relation to data protection at Qdos can be directed to Our Data Protection Champion, Steve Wade, who can be contacted by email at firstname.lastname@example.org, or by post at Windsor House, Troon Way Business Centre, Humberstone Lane, Thurmaston, Leicestershire, LE4 9HA.
2.3 We are authorised regulated by the Financial Conduct Authority as an appointed representative of Qdos Broker & Underwriting Services Ltd (FCA firm reference number 460886). This can be checked on the Financial Services Register at https://register.fca.org.uk.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 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 UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.2 date of birth;
5.4 business/company name;
5.5 trade or business activity;
5.6 annual turnover;
5.7 claims history;
5.8 contact information such as email addresses and telephone numbers;
5.9 financial information such as credit / debit card numbers and bank account details;
5.10 IP address;
5.11 web browser type and version;
5.12 operating system;
5.13 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 and GDPRat all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our insurance products and consultancy services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our insuranceproducts andservices for you;
6.2.6 Replying to emails from you;
6.2.7 Sending emails to notify you ahead of the renewal date of any insurance products you have purchased from Us;
6.2.8 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by following the instructions provided within those emails;
6.2.9 Market research;
6.2.10 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, orpost with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 Customer name and contact details will be retained for a period of seven years from the date on which the customer’s insurance policy last incepted. This is the period of time we are required to maintain records in order to comply with the terms of our binding authority with insurers and to comply with our regulatory requirements.
7.1 How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
7.2 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.3 Steps We take to secure and protect your data include:
7.3.1 All emails containing personal data must be encrypted. If the email cannot be encrypted, the personal data will be sent via other secure means (e.g. SFTP transfer);
7.3.2 All emails containing personal data must be marked “confidential”;
7.3.3 Personal data may only be transmitted over secure networks;
7.3.4 Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
7.3.5 Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient;
7.3.6 All personal data transferred physically should be transferred in a suitable container marked “confidential”;
7.3.7 No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from a Company Director.
7.3.8 All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;
7.3.9 No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;
7.3.10 Personal data must be handled with care at all times and should not be left unattended or on view;
7.3.11 Computers used to view personal data must always be locked before being left unattended;
7.3.12 No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the IT Manager and a Company Director and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
7.3.13 No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;
7.3.14 All personal data stored electronically should be backed up hourly with backups stored offsite. All backups should be encrypted;
7.3.15 All electronic copies of personal data should be stored securely using passwords and encryption;
7.3.16 All passwords used to protect personal data should be changed regularly and should must be secure;
7.3.17 Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
7.3.18 All software should be kept up-to-date. Security-related updates should be installed not more than 30 days afterbecoming available;
7.3.19 No software may be installed on any Company-owned computer or device without approval; and
7.3.20 Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Marketing Manager to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
8. Do We Share Your Data?
8.1 We may share your data with other companies in Our group for internal accounting, business analysis and regulatory compliance oversight. This includes Our holding company and its subsidiaries.
8.2 If you purchase an insurance product from Us, We will be required to share your data with the insurer(s) of those insurance products. The identity of the insurer(s) with which your data will be shared will be confirmed to you within our purchase process, and the terms and conditions of any insurance product we provide to you will contain data protection provisions that describe how they will in turn use your personal data.
8.3 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.4 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
10.1When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emailsandat the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site, to obtain quotations for an insurance product, or to take out an insurance product, you will be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com, or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy.
14. Contacting Us