This is the privacy notice of Norton Insurance Brokers Limited trading as Heritage Insurance Brokers (registration number:09908568) whose registered office is at 4 Vicarage Road, Edgbaston, Birmingham, B15 3ES referred to as we, us or our in this privacy notice.
This privacy notice sets out how we collect and process your personal data. This privacy notice also provides certain information that is legally required and lists your rights in relation to your personal data.
This privacy notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this privacy notice as personal data or personal information and further detail of what this includes are set out in this privacy notice below.
The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected by us at all times. Please read this privacy notice carefully as it explains how we may collect and use your personal data.
This privacy notice may vary from time to time so please check it regularly. This privacy notice was last updated on 1st July 2020.
HOW TO CONTACT US
Controller and contact details
For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller, we use (or process) the personal data we hold about you in accordance with this privacy notice.
If you need to contact us in connection with the use or processing of your personal data, then you can do so using our contact details as set out below.
Data Protection Representative
Our Data Protection Representative is Andrew McDonald, whom you can contact at Amcdonald@norton-ib.co.uk
WHAT INFORMATION WE HOLD ABOUT YOU AND WHERE WE OBTAIN THIS FROM
The personal data that we collect about you may include the following information:
• Personal data you provide to us in person, via our website or by telephone
• Personal data you provide when you enquire about insurance, or when you purchase a policy, through us, including information about what and/or who you want to insure, such as vehicle details, business activities, your home or travel details
• General information about you, such as your name, address, contact details and date of birth
• Personal data you provide if you subscribe to any of our mailing or newsletter services
• Your claims and credit history
• Financial details, such as your bank account and card details
• Criminal convictions
• Information about your use of our website such as your IP address, which is a unique number identifying your computer, including personal data gathered using cookies
In addition, we may obtain certain special categories of your data (special categories of data) and data about criminal convictions, and this privacy notice specifically sets out how we may process these types of personal data. The special categories of data are data concerning health.
We collect your personal data from you as a controller when we obtain quotations for insurance for you, when we set up your policy for you and when we make changes to your policy for you. This may also involve the collection of data from or about others who are associated with you and your insurance policy such as other persons insured on your policies or your employees or representatives. By giving us information about someone else for the purpose of arranging insurance for them under your policy such as named driver, employee or travel companion etc. you confirm that you have their permission to do so and that you have shared this privacy notice with them.
By asking us to arrange a contract of insurance for you where this involves passing information to us relating to children, you confirm to us that in doing so you are the responsible guardian of the child.
We also collect information from publicly available sources and third party databases made available to the insurance industry for the purposes of reducing fraud and financial crime as well as any other third party databases where your personal data may be held, provided such third parties have lawful bases on which to share such personal data with us.
HOW WE USE YOUR PERSONAL DATA AND THE LAWFUL BASIS FOR DOING SO
Where we are relying on a basis other than consent, we may rely on one or more of the following legal bases when processing your personal data for the following purposes:
|Purposes for which we process your personal data||The basis on which we can do this (this is what the law allows)|
|In order to perform our contractual obligations to you. This would include our fulfilling your requests for insurance services (including obtaining insurance for you, fulfilling requests for mid-term adjustments and obtaining renewals)||The processing is necessary in connection with any contract that you may enter into with us|
|To administer your account, including financial transactions for insurance broking||The processing is necessary in connection with any contract that you may enter into with us|
|To assist in the prevention and reduction of fraud and other financial crime||The processing is necessary for us to comply with the law and our legal requirements|
|In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded||The processing is necessary to pursue our legitimate interest in the management and operation of our business|
|To let you know about similar products and services that may be of interest to you||The processing is necessary to pursue our legitimate interest in operating our business|
|To make automated decisions, automated profiling and fraud detection||The processing is necessary in connection with some contracts that you may enter into with us|
SPECIAL CATEGORIES OF DATA AND CRIMINAL CONVICTIONS
We may also need to collect special categories of data from you such as information about your health, personal data revealing racial or ethnic origin, religious or philosophical beliefs or trade union membership and generic data. We may also collect information on criminal convictions which we may share with third parties. The lawful basis on which we can do this is the processing is necessary for reasons of substantial public interest relating to insurance purposes.
Insurance purposes mean (a) advising on, arranging, underwriting or administering an insurance contract (b) administering a claim under an insurance contract or (c) exercising a right or complying with an obligation, arising in connection with an insurance contract, including a right or obligation arising under an enactment or a rule of law.
WHO WE PASS YOUR PERSONAL DATA TO
We may need to pass your personal data to other companies which may include:
• Other companies or brands within our group of companies, for example if we are unable to provide a suitable insurance policy on request or at renewal we will check if any of our associated group companies can provide you with suitable cover
• The insurers, intermediaries and third-party service providers that we use for the purpose of arranging and administering your insurance policy. This may also include risk management assessors, uninsured loss recovery agencies, premium finance providers and other third parties involved (directly or indirectly) in the administration of your insurance and its associated benefits
• Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as claims handling, IT systems and administrative services and other activities set out in this privacy notice, as well as support activities such as finance and auditing services
• Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
• Other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid request from the police or other third-party organisation in the interest of preventing and detecting crime
• Fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud
• Credit reference agencies to check your credit history. This check will be recorded on your credit reference file without affecting your ability to apply for credit or other financial products
• Third parties we use to recover money you may owe us or to whom we may sell your debt
• Another company, if our business or part of it is bought or taken over by that company to make sure your insurance policy can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over
The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the UK and the European Union. We will only do so if there are adequate levels of protection in place as required by applicable data protection laws.
ACCESSING OUR WEBSITE AND COOKIES
When you visit one of our websites we may collect information from you, such as your email address, IP address and other online identifiers. This helps us to track unique visits and monitor patterns of customer website traffic, such as who visits and why they visit. We may use third parties to collate IP addresses to help us understand our Internet traffic data and data regarding your browser type and computer. We may also use web usage information to create statistical data regarding the use of our website. We may then use or disclose that statistical data to others for marketing and strategic development purposes, but no individuals will be identified in such statistical data.
Internet browsers normally accept cookies by default, although it’s possible to set a browser to reject cookies. We’ll ask your permission before using any cookie that’s not essential to the email or the use of the website. However, refusing to accept cookies may restrict your use of our website and/or delay or affect the way in which our website operates. You can find more information on cookies when you visit our website.
The open nature of the internet is such that data may flow over networks without security measures, and may be accessed and used by people other than those for whom the data is intended. While this is outside of our control, we do take the protection of your information very seriously and aim to apply appropriate levels of security at all times.
CLOSED CIRCUIT TELEVISION (CCTV)
Where CCTV is used, we have identified and documented the potential impact on individuals’ privacy and have taken this into account when installing and operating the CCTV system. We regularly review whether CCTV is still the best security solution.
We will clearly inform individuals of our use of CCTV and we only retain recorded CCTV images for long enough to allow for any incident to come to light (e.g. for a theft to be noticed) and to investigate it. We will respond to individuals or organisations making requests for copies of their images on our CCTV footage and will seek prompt advice from the Information Commissioner where there is any uncertainty. We securely store CCTV images, limit access to authorised individuals and regularly check that the CCTV system is working correctly. We have a nominated individual who is responsible for the operation of the CCTV system.
We will only store your data for as long as is necessary to comply with the requirements of your insurance contract(s) and any legal obligations or lawful processing conditions that may exist as a result. You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep you information. If this is the case, we’ll let you know our reasons.
You can ask us to:
• Provide a copy of your personal information
• Correct or delete unnecessary or inaccurate personal information
• Restrict or to object to the use of your personal information at any time
• Object to any automated decision, including profiling which may have been used by insurers when underwriting your quotation. Where an automated decision has been made we will advise you of this and of your rights.
• Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you.
• Where we rely on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you don’t want us to contact you again.
If you have any questions or concerns about this privacy notice or your data protection rights please contact us using our details set out at the beginning of this privacy notice.
You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement. Further details about the ICO are available at www.ico.org.uk.
HOW WE CONTACT YOU ABOUT OTHER PRODUCTS AND SERVICES
We may from time to time process your personal data to let you know about similar products and services that may be of interest to you. This is because we value your custom and we pride ourselves in offering professional and tailored advice which meets your specific insurance needs. This includes keeping you informed on the latest insurance and industry information and details of any offers or promotions relating to the insurance services we provide to you. Our lawful basis for processing your personal data in this way is as is necessary to pursue the legitimate interests of our business, unless we have otherwise obtained your consent to do so. We may contact you by post, telephone or e-mail. You will be given the option to stop receiving any communications from us in this regard at any time however please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.
Cookies are small text files that may be automatically stored on your computer or mobile device by the websites you visit. We use the following types cookies:
- Strictly necessary. Required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Provider | Adroll
Cookie | __ar_v4
Description | Third party cookies used for advertisement personalisation and tracking. More Information can be found here (https://www.adroll.com/en-GB/about/privacy).
Usage Type | 4. Targeting
Expiry | < 6 Years
Provider | Bing
Cookie | _uetsid
Description | We use Bing Analytics to gain a better understanding of how users browse and interact with our website and advertisements in order to improve our website and offer a better user experience. More Information can be found here (https://privacy.microsoft.com/en-gb/privacystatement).
Usage Type | 2. Analytical
Expiry | 1 Hour
Provider | Google
Cookie | _ga
Description | We use Google Analytics and Google Tag Manager to gain a better understanding of how users browse and interact with our website in order to improve our website and offer a better user experience for everyone.
Cookie | _ga: Used in combination with the _gid to distinguish users and generate statistical data.
Cookie | _gid: Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
Cookie | _gat_UA-###: Used by Google Analytics to throttle request rate.
Cookie | _dc_gtm_UA-###: Your unique Analytics ID used by Google Tag Manager to generate visitor and statistical data.
Usage Type | 2. Analytical
Expiry | 2 Years
Cookie | _gid
Expiry | 24 Hours
Cookie | _gat_UA-#######
Expiry | 1 Minute
Cookie | _dc_gtm_UA-###
Expiry | 1 Minute
Analytics cookies on our website
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The information generated by the cookie about your use of this website (including your IP address) will be transmitted to a Google server in the USA and stored there. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activities for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where this is required by law or insofar as third parties process this data on behalf of Google. Google will never associate your IP address with any other data held by Google.
For more information about Google Analytic cookies please visit (https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage).
Managing / Blocking Cookies:
Please see the links below for instructions on limiting cookies for your browser:
> Safari (https://support.apple.com/kb/ph21411?locale=en_GB)
> Opera (https://help.opera.com/Windows/10.20/en/cookies.html)
> Mozilla Firefox (https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences)
> Google Chrome (https://support.google.com/chrome/answer/95647?hl=en&hlrm=en)
> Internet Explorer (https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies)
To opt out of being tracked by Google Analytics across all websites, you can install a small plugin proposed by Google for all major browsers.
For more information you can visit Google (https://tools.google.com/dlpage/gaoptout).
“Even in these difficult times it was reassuring to have a friendly voice on the phone to sort my policy out. Top marks again for making a chore a pleasure.” – 5 stars, single vehicle insurance customer.
Top marks for making a chore a pleasure
“Excellent service. Could not be easier to renew my insurance policy. Would recommend to anyone.” – 5 stars, multi car customer
Could not be easier
“The lady who dealt with me was exceptionally helpful. Listening to all my requirements and responding to all my needs. Thank you” – 5 stars, multi car customer
“30 years with the same insurer because they are the best all round. Thanks.” – 4 stars, single vehicle insurance customer
30 years with the same insurer
“Very helpful staff. I dealt with Faisal and Emmanuel. Please thank them from me.” – 5 stars, single vehicle insurance customer
Very helpful staff
“Spoke to 2 different staff and both very helpful, especially as they were both working from home due to the lockdown.” – 5 stars, multi car customer
Very helpful, especially as they were working from home
“Have been with Heritage for ten yrs, and I have always had good efficient service, at a realistic price. The staff are very polite and helpful, Will keep using them :-)” – 5 stars, single vehicle insurance customer