Aequitas Automotive Privacy Policy

Policy Last Updated 08th Jan 2020

Introduction

Aequitas Automotive Ltd, trading as Totallossgap.co.uk, GapInsurance123.co.uk, Easygap.co.uk, Shortfall.co.uk and TyreInsurance123.co.uk, understands your concerns over the privacy of Personal Data you may provide to us as part of our day to day dealings with you. We will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.

This policy provides you with information about what types of information are collected, retention periods and other elements to comply with the EU Wide - General Data Protection Regulation and the UK’s Data Protection Bill 2018.

If you have any questions about this Privacy Policy or our treatment of your Personal Data please contact us using the details given below.

If you are dissatisfied with this response you may request that your complaint be escalated, in which case it will be escalated to a member of the Aequitas executive team who will review your complaint and the initial response and provide a further response within 28 days of your request to escalate the matter.

If we are unable to resolve your complaint, you may make a complaint to the Information Commissioner’s Office (if based in the UK, otherwise to your local Supervisory Body). Please see https://ico.org.uk/for-the-public/raising-concerns for more information.

Whilst this privacy policy sets out a general summary of your legal rights in respect of your Personal Data, this is a complex area of law and this privacy policy is not intended to represent legal advice. More information about your rights in respect of your Personal Data can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public

Who we are

• Aequitas Automotive Ltd, Aequitas House, 56 Hamilton Square, Birkenhead, Merseyside, CH41 5AS

• Contact Information Data Officer – Mark Griffiths

• 0151 647 7556

• Email – [email protected] (please mark data enquiries 'Subject Data/Privacy')

Key Terms

The following terms are used or referred to in this privacy notice – as such it helps to be familiar with these core terms:-

• ‘Data Controller’ – company/individual that determines the purposes and means of the processing of personal data (typically this refers to us when we market to you, and your employer when they provide personal details about you)

• ‘Data Processor’ – Company/Individual which processes personal data on behalf of the controller. This is typically a company that provides services to your employer e.g. IT company.

• ‘Data Subject’ – The individual about who the data is held (you, or your employees in the case of a Company who have asked us to provide services on their behalf)

• ‘Consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes signifies agreement to the processing of personal data relating to him or her. This is typically used by us to provide marketing services to you.

Our approach to your data

We only keep your data for as long as we need to in order to use it as described in this policy, typically per statutory requirements/ and or as long as you are an active client.

Data security is of great importance to Us, and to protect your data, We have put in place suitable physical, electronic and organisational procedures to safeguard and secure data such as your personal data.

Some examples of steps we have taken to secure your data include :-

• Cyber Essentials Certified which demonstrates we have implemented 5 core cyber security best practices

• Meeting the IASME – Information Assurance for Small/Medium/Enterprises which covers a risk-based approach to information security

   

Where we send your data

Aequitas Automotive Ltd will only transfer your data to third parties within the EEA.

Information and Data we collect and why

Personal Data is anything which identifies you as an individual, either on its own or by reference to other information. If you are engaging with us to provide services this also applies to any information you share with us.

In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the products and services We can provide you without your consent for Us to be able to use such data.

Aequitas Automotive Ltd act primarily as an insurance broker. The primary products we provide would include Gap Insurance, Tyre Insurance, Alloy Wheel Insurance, Cosmetic Repair Insurance and Motor Excess Insurance. Aequitas Automotive Ltd can also act as a credit broker if you apply for a premium credit agreement to pay for the goods and services we may arrange on your behalf.

When you apply for goods or services from Aequitas Automotive Ltd we may request a number of aspects of personal data in order to comply with the contractual execution of your insurance contract. These may include :

• Full Name

• Address

• Date of birth

• Telephone number

• Email address

When you elect to pay for your product or services we may require credit or debit card details to do this. These details are entered directly to a third party car processor gateway (we currently use Braintree and PayPal for that purpose). You may elect to apply for a premium credit agreement to pay for your goods and services over a set term (currently Aequitas Automotive Ltd act as a credit broker in that case, and will ask for bank details to pass to Premium Credit PLC to process that application).

Aequitas Automotive Ltd do not retain payment details and, as soon as the details are entered on the third party gateway, Aequitas Automotive Ltd cannot access payment details again.

Aequitas Automotive Ltd do record incoming and outbound calls for training and monitoring purposes. Aequitas Automotive Ltd does not record sections of the call that detail any payment methods that may be provided in order to pay for your product or service.

Data Retention Policy

We only keep your data for as long as we need to in order to use it, and/or for as long as we have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.

Some of your personal data will need to be kept to meet either contractual or legal requirements. These may include contractual performance of your insurance policy, tax, regulatory or where we need to establish, bring or defend a legal claim.

Aequitas Automotive Ltd will retain your personal information for a period of 6 years from when your policy expires or from when you provided your data for quotation or enquiry purposes. After this time your data will be deleted.

This will apply unless:

• the law requires us to hold your personal information for a longer period, or delete it sooner;

• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;

• we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or

• in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

   

Our Website(s)

We have a website which also collects details about you including your IP address and we may also use a technical feature called a cookie to record your visits.

We will only use your personal data for providing and managing access to our website and if appropriate tailoring your experience whilst visiting.

What Cookies Do We Use and What For?

Our website may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

By using Our Site you may also receive certain third-party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for analytical and advertising purposes. These cookies may include Google Analytics and Google AdWords Remarketing cookies.

All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.

Can you disable Cookies?

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

For more information on how to use and disable Cookies, as well as in depth information as for their uses in the UK, please refer to http://www.youronlinechoices.com/uk/

Are Cookies safe?

Yes, they are small text files that enable our website to recognise a user for a single visit or a return visit. They do not contain data such as your date of birth or payments details.

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

Marketing

We will market to existing customers where the information/notification is related to existing services only.

For sales related marketing activities - we will require consent and for you to take an affirmative action, furthermore you will have the option to opt-out (unsubscribe at any point). As per your rights – you may also object to direct marketing and we will cease all related activities (unless they impact our ability to deliver our contracted services to you – if you are an existing customer).

We will also market to you in relation to services and products we offer, where we have a commercial agreement/contract with you.

Should you wish to Opt Out of marketing please do so by one of the following methods.

• Click the unsubscribe link in the email that you have been sent

• Email us, using the subject matter 'unsubscribe' to [email protected]

• Write to us at Aequitas Automotive Ltd, Aequitas House, 56 Hamilton Square, Birkenhead, Merseyside, CH41 5AS

Please note that any request to 'opt out' will be dealt with as promptly as possible but there may be a small delay during which time you may still receive contact and/or marketing.

How we process your personal data and the legal basis for doing so

Lawful Basis

Any personal data that is collected/processed must be processed in a lawful manner, this section details on what basis we may do this, and this can be dependent on the method by which the data is provided.

Personal Data

We process the personal data where the lawful basis is Consent where the documented purposes of processing are to provide services/products, examples include : -

• Contacting you via a web contact/email sent in by you, using the contact details you provide (email or telephone number)

• To provide you a quotation by email and further reminders when the validity of that quotation may expire

We process the following personal data where the lawful basis is Performance of a Contract where the documented purposes of processing are to provide services/products, examples include : -

• Where you engage Aequitas Automotive Ltd to provide broker services in order for you to purchase a policy and enter a contract of insurance with one of our insurers

• Where you provide bank details in order for Aequitas Automotive Ltd to provide credit broker facilities in regards to the application for a premium funding agreement

We process the following personal data where the lawful basis is Legal Compliance where the documented purposes of processing are to provide services/products, examples include : -

• Where we may be required to pass data to authorities for suspected fraud or criminal activity

• Where we are required to provide data to regulators investigating our business activity

We process the following personal data where the lawful basis is Legitimate Interests where the documented purposes of processing are to provide services/products, examples include : -

• In providing you with details on products and services that you may be interested in. These will be closely related in nature to our core business, i.e. your motoring protection and needs

• Sending you email notification of the expiry of your policy and any options you may have for renewal

Data Sharing

In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, administration and underwriting of your contract of insurance, 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.

We will share data with the third parties listed below:

• Insurer of your policy (as detailed on your policy schedule)*

• Claims Administrator of your policy (as detailed on your policy schedule)

• Payment processing provider (currently Braintee and PayPal)

• Premium credit agreement provider (currently Premium Credit PLC)

Please note that this notice does not cover the Privacy Policy details of third parties we may share your data with. Please check the individual Privacy details provided by the companies detailed on your product or service.

Please note this Privacy Notice does not cover details of any links outbound from our websites.

What Happens If Our Business Changes Hands?

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

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.

Your rights

As an individual you have rights associated with your data :-

1. Right of access by the data subject . You (the data subject) shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and related information.

2. Right to Rectification – from the controller without undue delay the rectification of inaccurate personal data concerning him or her

3. Right to Erasure – the right to obtain from the controller the erasure of personal data concerning him or her without undue delay – subject to suitable grounds.

4. Right to Restriction of Processing– the right to obtain from the controller restriction of processing where certain rules apply

5. Right to notify any recipients – where data is shared within relation to the Articles 16, 17 and 18 above.

6. Right to data portability – to receive personal data concerning him/her which they have provided to a controller

7. Right to Object – on grounds relating to his/her situation

   • where the lawful basis is legitimate interests.

   • applies to direct marketing purposes.

Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our websites (GapInsurance123.co.uk, Easygap.co.uk, Totallossgap.co.uk, Shortfall.co.uk and TyreInsurance123.co.uk) and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our websites following the alterations.

Please check our Privacy Policy page regularly for any updates.