1st Choice Insurance
Privacy Policy

This page explains the privacy policy for 1st Choice Insurance and how we will use and protect any information about you that you give us when you visit this website.

This privacy statement only covers this website www.1stchoiceinsurance.co.uk. It does not cover any sites that you can link to from this site so you should always be aware when you are moving to another site and read the privacy statement on that site. This privacy policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

This is the privacy notice for Broker Business Direct Ltd (T/A 1st Choice Insurance)

Broker Business Direct Ltd respects your privacy and is committed to keeping your personal data protected. This privacy notice will inform you how we manage or hold your personal data in the following circumstances:

  • When you visit our website.
  • When you provide it to us directly.
  • When provided indirectly via a third party such as a partner company (a lead generation company).

This policy is set out as follows:

  • Important Information and who we are
  • The Data we collect about you
  • How your personal data is collected
  • How we use your personal data
  • Disclosures of your personal data
  • Data Security
  • Data Retention
  • Your Legal Rights
  • Complaints
  • Glossary
  1. IMPORTANT INFORMATION AND WHO WE ARE

WHO WE ARE

Broker Business Direct Ltd (trading as 1st Choice Insurance), is a company which is incorporated in England & Wales with the number 08273092, and is registered under the Data Protection Act.

Broker Business Direct Ltd undertakes a diverse range of activities, a number of which are regulated by the Financial Conduct Authority.

Where you have provided your personal information to us directly we will be the Data Controller and where we have received your personal information via a third party, we will perform the role of a Data Processor on behalf of the Data Controller.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights under the Data Protection Act please contact the DPO using the details set below.

CONTACT DETAILS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This privacy notice was last updated August 2020

The data protection law in the UK will change on the 25th May 2018. This privacy notice sets out your rights under the new laws, however is subject to change on or after the 25th May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, employment status, marital status, title, date of birth and gender.
  • Contact Data includes home address (previous, current and forwarding), email address and telephone numbers.
  • Personal Data includes your profession, employer, income, driver history, convictions, no claims bonus and any other reasonable information that would aid us to get an insurance quote.
  • Property Data includes where you live and how long you have lived there.
  • Financial Data includes bank account details and your credit file. We may also ask for business financials such as wage bill, turnover and profits.
  • Transaction Data includes card payment details & details about payments to and from you. Other details of products and services you may have purchased from us.
  • Technical Data includes Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, products and services. Please follow Google’s Privacy Policy for more information.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Unless we have a legitimate interest, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, we do collect any information about criminal convictions and offences, and also financial data such as CCJ’s and we may access your credit file. This may mean we have to refer the request and therefore your data to a third party credit checker who is also regulated by the Financial Conduct Authority.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. We will give you at least 7 days notice and this will be delivered via text message and email.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including:

Direct interactions. You may give us your Identity, contact, addresses, employment information, vehicle information, and driver history by filling in online forms, telephone or handwritten application forms. This includes personal data you provide when you:

  • Register your details onto our website seeking insurance quotes.
  • Request marketing to be sent to you.
  • Supply us with feedback/reviews.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below. Technical Data from the following parties:

  • Analytics & tracking providers some such as Google based outside the EU
  • Google Tag Manager
  • Google Analytics
  • Advertising networks
  • Google Adwords
  • Lead Pages
  • Facebook ad
  • Twitter
  • Linkedin
  • Paid Display Adverts
  • Quotesearcher
  • Quotezone
  • AutoSLM
  • Policy Link
  • Wiser Connect
  • Other lead generation providers
  • WordPress Plugins
  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • When we receive a request to find an insurance quote.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where data is held for our/your legitimate interests (or those of a third party), fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

We only rely on consent as a legal basis for processing your personal data in relation to marketing communications to you via phone, email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, some of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
We receive a insurance quote request.

(a) Identity

(b) Contact

(c) Personal

(d) Financial

To provide an accurate insurance quote.
Insurance Updates

(a) Identity

(b) Contact

Legitimate interest of the applicant/customer
Submit your personal information to our Financial Services Provider. We will also share data with our panel of A rated insurers. We also send data to finance companies.

(a)Identity

(b)Contact

(c) Personal

(d) Financial

Necessary for our legitimate interest to conduct a financial qualification check/access accurate quotes prior to entering a contract.

To process your order including:

Managing payment methods, and take deposits

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

Performance of a contract with you
   

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Personal

(d) Financial

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

MONITORING PHONE CALLS

Telephone calls using the telephone numbers provided on this website and all 1st Choice Insurance extensions and e-mail correspondence with 1st Choice Insurance via generic or individual employees e-mail addresses may be recorded or monitored. By using such communication methods you are consenting to the recording or monitoring of the same. We use this data for training and quality purposes. It is also our duty to ensure you have access to any information which entered you into a contract, as part of our corporate responsibility.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage, Financial and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Broker Business Direct LTD of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

COOKIES

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. By using the website you are agreeing to using cookies. Cookies contain information that is transferred to your computer’s hard drive. Our sites may use one or more of the following sorts of cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our websites. They include, for example, cookies that enable you to log into secure areas.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around a website when they are using it. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to a website. This enables us to personalise our content for you and remember your preferences.
  • Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to make our websites and the advertising displayed on it more relevant to your interests.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Most browsers are initially set to accept cookies, but if you prefer, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about cookies, please see (http://www.aboutcookies.org/)

The technology used in the 1st Choice website does not currently use cookies, but we reserve the right to introduce their use without notice.

1st Choice does not currently log user IP addresses (the location of your computer on the internet) but we reserve the right to for systems administration and trouble-shooting purposes. We do not log IP addresses to track a user’s session, nor do we link IP addresses to anything personally identifiable. Your browser will also inform us of the type of computer or operating system being used by you.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We will not sell or transfer any information that you supply to any third party. The information which we collect will be handled in accordance with the General Data Protection Regulations (GDPR). We will not pass your details to any external organisation or third party without your permission. 1st Choice Insurance reserves the right to access and disclose individually identifiable information to comply with applicable laws and lawful government requests, to operate its systems or to protect itself or its users. We will always make sure we have your consent, should we ever need to pass data on to a third party.

Transferring leads to a third party

If we are uncompetitive we may transfer your data to a third party 1st Choice partner company, who we know are best placed to give you the most cost effective quote for your insurance needs. We will only transfer your data for legitimate interest purposes to companies who we know, trust and have a working relationship with. Leads may be transferred to one of our key partners, either Policy Link or Wiser Connect Ltd. These leads will be sent via email, API or phone call. You have the right to request we do not share your personal data, simply drop an email to the marketing department on marketing@1stchoiceinsurance.co.uk.

  1. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Broker Business Direct LTD and all websites owned by BBD LTD, are highlight secure with full encryption certificates in place. In addition, we limit access to your personal data to third parties who have a business. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We will always ask for permission to send targeted marketing communications to you at your renewal date. We do this under the assumption of legitimate interest.

We will also assume a legitimate interest to send you communications at your renewal date, as you are a current, satisfied customer.

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. COMPLAINTS

Complaints procedure if you wish to register a complaint regarding Insurance products, please contact us:

By email: please send us your complaints to: dataprotection@1stchoiceinsurance.co.uk

By phone: call us on 01743 770 500

In writing: send a letter to: Data Protection Officer, 1st Choice Insurance, Jupiter House, Sitka Drive, Shrewsbury Business Park, Shrewsbury, SY2 6LG

  1. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

EXTERNAL THIRD PARTIES

  • Service providers acting as processors based in the United Kingdom who provide:
  • IT and system administration services.
  • Feedback and service references
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have a right to access your information to check whether it is accurate and up to date. Should you wish to access or amend information held about you, or if you have any other queries on 1st Choice Insurance privacy policy or site security please contact us.

Access to your information and contacting 1st Choice Insurance

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

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