Privacy Policy
This Privacy Notice was last reviewed on 25 March 2022
INTRODUCTION
For the purpose of this Privacy Policy, “you” or “your” means (as applicable): (i) the individual representatives or end users of any of our customers or vendors; (ii) the individual users of our Platform or visitors to www.quotech.io our (“Website”); and (iii) individuals from whom we collect Personal Data that is publicly available or is available from financial databases or similar sources. “we”, “us”, or “our” means Quotech Ltd, a company incorporated in England and Wales with company number 12384580 and registered office at 63/66 Hatton Garden, Fifth Floor Suite 23, London, England, EC1N 8LE.
This Privacy Notice sets out the basis on which any Personal Data we collect from you, that you provide to us, or that we collect from third parties will be processed by us. This Privacy Notice also sets out how you can instruct us if you prefer to limit the use of that Personal Data, and the procedures that we have in place to safeguard your Personal Data. Please read the following carefully to understand our processes and practices regarding your Personal Data and how we will treat it.
Quotech has developed an online Platform, that allows its insurance industry customers (insurance companies’ personnel, insurance brokers, etc.) subscribed to the Platform to more efficiently produce insurance quotes and administer insurance policies for the clients of the underwriters (the “Platform”).
1. IMPORTANT INFORMATION AND WHO WE ARE
This Privacy Notice applies to all Personal Data we process as a controller, in accordance with “Applicable Data Protection Legislation”, which means: (i) in the EU, all applicable data protection and privacy legislation in force from time to time, including but not limited to the General Data Protection Regulation ((EU) 2016/679) (“GDPR”); and (ii) in the UK, the GDPR until such time it is repealed or ceases to apply in the UK and all applicable data protection and privacy legislation in force from time to time including but not limited to the Data Protection Act 2018 (as applicable).
If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the details set out below:
- Full name of legal entity: Quotech Ltd
- Email Address: compliance@quotech.io
- Postal Address: 2 Leman Street, Aldgate Tower, London, E1 8FA
You have the right to make a complaint at any time to the supervisory authority for data protection issues, the Information Commissioner’s Office of the United Kingdom (the “ICO”). Please see their website for further details on how to make a complaint (https://ico.org.uk/). We would, however, appreciate the chance to address your concerns before you approach the ICO, so please contact us in the first instance.
2. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We review this Privacy Notice regularly. Please check back frequently to see any updates or changes to the Privacy Notice.
It is important that any Personal Data we hold about you is accurate and up to date. Please keep us informed if your Personal Data changes during your relationship with us.
3. THIRD-PARTY LINKS
Our website may include links to third-party websites 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 notices.
4. 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 individuals, as applicable such as:
- Identity Data includes surname and first name, mailing address, email address, phone number, and login details.
- Professional Data includes in relation to an individual, company name, company number, company address, job title, post, position, and business sector (and “know your customer” data when we onboard new customers).
- Technical Data includes the internet protocol (“IP”) address(es) used to connect your computer(s) to the internet, your login data, 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 our Website or our Platform.
- Customer Profile Data includes: as regards to our customers, details of any services commissioned, or supplied, and any queries, comments or complaints sent us by their personnel in relation to our business relationship with them.
- Usage Data includes information about how the end users use our Website, our Platform or our other services and how our vendors access any of them (to supply their services to us).
- Marketing and Communications Data includes your preferences regarding your receipt of newsletters or other marketing from us, and your communication preferences.
- Vendors Financial Data: in connection with vendors that provide services to us, their financial details (when such details include Personal Data) to allow us to pay their fees.
Unless we obtain your informed consent, or it is otherwise required by law in connection with a contract we have with you, we do not collect any Special Categories of Personal Data.
Where we are required by law, or under the terms of a contract we have with you, to collect Personal Data, and you fail to provide that data when requested, we may not be able to perform any contract with you. If this happens, we will notify you.
5. HOW WE COLLECT YOUR PERSONAL DATA
We collect your Personal Data through a number of methods, including:
- Direct InteractionsYou may give us your Identity, Contact, and Marketing Data, by filling in forms on our Website or Platform, or by corresponding with us by post, phone, email or otherwise.
- Automated Technologies or InteractionsAs you interact with our Website or Platform, we will automatically collect Technical and Usage Data from your equipment, browsing actions, and patterns.
- Third Parties or Publicly Available SourcesWe may collect Risk Assessment Data from publicly available sources or third parties.
6. 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:
- Where we need to perform the contract we are about to enter into or have entered into with the company you represent or work for;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your Personal Data, although we will get your consent (or rely on soft opt-in) before sending third party direct marketing communications to you via email or text message (see Section 7 below). You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in table format, a description of how we plan to use your Personal Data, and on which legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note that we may process your Personal Data for more than one lawful ground depending on the specific purpose.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To onboard a new customer |
(a) Identity Data (b) Professional Data |
Performance of the contract with your company Necessary to comply with a legal obligation |
To keep records of the services we provide to our corporate customers, and to their end users, and their usage of our services |
(a) Identity Data (b) Professional Data (c) Customer Profile Data (d) Usage Data |
Performance of the contract Necessary to comply with a legal obligation Necessary for our legitimate interests (for running our business) |
To keep records of the services we receive from our vendors, and their bank details to pay their fees |
(a) Professional Data (b) Usage Data (c) Vendors Financial Data |
Performance of the contract Necessary to comply with a legal obligation Necessary for our legitimate interests (for running our business) |
Assessing insurance related risks and creditworthiness of companies and their key personnel |
(a) Professional data (b) Risk Assessment Data |
Necessary for our legitimate interests (for running our business) |
To administer and protect our business, our Platform and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity Data (b) Professional Data (c) Technical Data (d) Usage Data |
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) Necessary to comply with a legal obligation |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Customer Profile Data (b) Usage Data (c) Technical Data |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website and our Platform updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to our customers or potential customers about goods or services that may be of interest to them |
(a) Identity Data (b) Professional Data (c) Customer Profile data (d) Usage Data (e) Technical Data |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
AGGREGATED DATA.
We may share anonymised and aggregated information about users of our services and information collected from providing those services, such as, but not limited to, by publishing a report or providing information to our business partners on trends.
MARKETING AND PROMOTIONAL OFFERS
We may use your Identity, Professional, Technical, Usage, 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 our services and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your Personal Data with any third party 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 or service purchase, product/service experience, or other transactions.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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.
7. DISCLOSURE OF YOUR PERSONAL DATA
We may share your Personal Data with the parties set out below, for the purposes set out in Section 6 above:
- Business partners where doing so is necessary for the performance of our contractual relationship with them (always in accordance with Data Protection Legislation);
- Vendors who provide Quotech with IT and system administration services;
- Professional advisers including lawyers, bankers, auditors and insurers;
- HM Revenue & Customs (United Kingdom), regulators, and other authorities; and
- any third parties to whom we may choose to sell, transfer or merge parts of the Quotech business or assets.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes, and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
8. INTERNATIONAL TRANSFERS
Quotech does not transfer Personal Data outside the European Economic Area (“EEA”) or the United Kingdom (as applicable). The Personal Data that we collect from you will be transferred to, and stored at, a destination inside the EEA or the United Kingdom (as applicable). It will also be processed by staff operating inside the EEA or the United Kingdom (as applicable) who work for us or for one of our third-party service providers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
9. 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. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. 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 if we are required to do so.
10. HOW LONG WE WILL USE YOUR PERSONAL DATA FOR
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Please contact us using the contact details set out in this Privacy Policy if you have any questions about data retention.
11. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If you wish to exercise any of your legal rights, please contact us using the contact details set out in this Privacy Policy.
You have the right to:
- Request access to your Personal Data.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. 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 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; and (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.You can 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.
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 could refuse to comply with your request in these circumstances. We will notify you if this is the case at the time.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month to respond if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
EXCEPTIONS
It may not be possible for us to delete your Personal Data if we are required to keep it by law, or if we hold it in connection with a contract with you. Similarly, access to your Personal Data may be refused if making the information available would reveal Personal Data about another person or if we are legally prevented from such disclosure.