Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of all categories of personal data that we use viz;

• (A) Broker Insights’ Prospective Clients & Website Visitors.
• (B) Broker Insights’ Platform Users.
• (C) Employees.
• (D) Broker Client Data.
• (E) Other Personal Data received from Insurers, Brokers and Stakeholders.

1.2 This policy applies where we are acting as;

• (A) A data controller with respect to the personal data of Broker Insights’ website visitors i.e.  where we determine the purposes and means of the processing of that personal data.
• (B) A data controller with respect to the personal data of Broker Insights’ platform service users.
• (C) A data controller with respect to employee personal data.
• (D) A data processor with respect to personal client data received from partner brokers as part of the contractual arrangements.
• (E) A data processor with respect to personal data received from insurers, brokers or stakeholders.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. You will be able to amend your choices at any time (see section 6 below).

1.4 In this policy, “we”, “us” and “our” refer to Broker Insights Ltd. [For more information about us, see Section 11.]

2. How We Obtain and Use Your Personal Data

2.1 In this section we have set out:

• Where we get your data from.
• The general categories of personal data that we may process.
• The purposes for which we may process your personal data.
• The legal bases for the processing.

(A) Broker Insights’ Prospective Clients & Website Visitors

We will process your personal data if you use our ‘Contact Us’ option on our website or contact us by phone or email, at trade shows or on social media etc. This will include data like name, email address, telephone number etc and will be used to enable us to respond to requests. The data will be retained during the period it takes to investigate and respond a query but may be retained longer while the contact is a prospective client. Prospective clients can also consent to receive the Broker Insights newsletter. Personal data will be deleted when the potential client is no longer a prospect, and this will be undertaken during an annual review.

We may process data about your use of our website. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services.

The legal basis for this processing is our legitimate interests, namely responding to contact requests and monitoring and improving our website.

(B) Broker Insights’ Platform Users

We will process your personal data that is required for you to access the platform services. This will entail your name, company email address and phone number. Platform users will receive email correspondence as part of the service processes. This data will be deleted when access is no longer required as specified by the insurer or broker or the end of the contractual arrangement.

We may process data about your use of platform services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services.

The legal basis for this processing is for the fulfilment of a contract.

(C) Employees

We will process your personal data that is required for fulfilling the requirements of the company’s employment contract. This may include some special category data. This will entail name and address, date of birth, personal email address, National Insurance number, mobile phone number, home telephone number, emergency contact details, passport image, driver’s license, medical details.

The legal basis for this processing is for the fulfilment of a contract. Data will be retained for up to six years after the end of employment so as to comply with the statutory requirement regarding employment data.

(D) Broker Client Data

The commercial client data received from our partner brokers will include some personal data. This may entail names, email address, physical address, business address, business name. The processing undertaken by Broker Insights will be to assist the engagement between insurers and brokers to increase the likelihood of the successful placement of brokers’ client business.

The legal basis for this processing is for the fulfilment of a contract. Data will be retained for six years to comply with The Limitation Act 1980.

(E) Other Personal Data received from Insurers, Brokers and Stakeholders

We may receive personal data for prospective clients from insurers, brokers or other stakeholders. This will include data like name, email address, telephone number etc and will be used to enable us to investigate the business opportunity. The data will be retained during the period it takes to investigate the business opportunity but may be retained longer while the contact is a prospective client. Personal data will be deleted when the potential client is no longer a prospect, and this will be undertaken during an annual review. The legal basis for this processing is our legitimate interests.

2.2 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.3 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legal obligation, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

2.4 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.5 We may process general data e.g. potential client contact details obtained from ad hoc sources e.g. personal recommendation from a current client. The legal basis for this is legitimate interests.

2.6 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

(F) NPS Data Processing and Collection

At Broker Insights, we use Net Promoter Score (NPS) surveys to enhance our services and assess customer satisfaction, collecting data through surveys, emails, and feedback forms. This data helps us identify areas for improvement and respond to feedback, and its processing is based on our legitimate interests in service enhancement. We securely store NPS data for analysis and internal purposes only and use a third-party survey platform to facilitate the survey process. Participation in NPS surveys is voluntary and you can opt out at any time.

3. Your Rights

3.1 Your Right of Access

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can raise a Subject Access Request using the Contact Us page on our website and choosing the ‘Subject Access Request’ enquiry type.

3.2 Your Right to Rectification

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

3.3 Your Right to Erasure

You have the right to ask us to erase your personal information in certain circumstances.

3.4 Your Right to Restriction of Processing

You have the right to ask us to restrict the processing of your information in certain circumstances.

3.5 Your Right to Object to Processing

You have the right to object to processing if we are able to process your information because the process forms part of our public tasks or is in our legitimate interests.

3.6 Your Right to Data Portability

This only applies to personal information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or in talks about entering into a contract and the processing is automated.

You are not required to pay any charge for exercising your rights. We have one month to respond to you.

4. International Transfers of your Personal Data

4.1 In Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 We currently do not have offices and facilities in any country other than the UK. On initial sign up to our newsletter your email address will be held securely in the USA.

4.3 The hosting facilities for our website are situated in the UK.

4.4 The European Commission has made an “adequacy decision” with respect to the data protection laws of each of the countries in which Broker Insights service providers operates. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from

https://ec.europa.eu/info/law/law-topic/data-protection_en

4.5 You acknowledge that personal data that you authorise for publication on our website (e.g. a testimonial) may be available via the internet around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Sharing Your Data

We will not share your information with any third parties for the purposes of direct marketing.

We use data processors who are third parties who provide services to us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do so. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Third Party Processors

• Finling Associates Ltd – Accountants
• Blackadders LLP – Solicitors
• 121 HR Solutions – HR Consultancy Partner
• BreatheHR – HR software service
• Campaign Monitor and/or Transpond – Email marketing and automation services
• Docusign – Electronic document signature service
• Microsoft 365 – Office application service
• Capsule CRM – Customer Relationship Management service
• Experian – Data Enhancement
• SurveyMonkey – Customer Survey Tool

6. About Cookies

Our website uses cookies to operate successfully. Some of these cookies are essential, while others help us to improve your experience by providing insights into how the site is being used.

6.1 A cookie is a file containing an identifier a string of letters and numbers that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

6.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

6.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies That We Use

6.4 We use cookies for the following purposes:

• (a) authentication – we use cookies to identify you when you visit our website and as you navigate our website
• (b) status – we use cookies to help us to determine if you are logged into our website
• (c) personalisation – we use cookies to store information about your preferences and to personalise the website for you
• (d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
• (e) advertising – we use cookies to help us to display advertisements that will be relevant to you
• (f) analysis – we use cookies to help us to analyse the use and performance of our website and services
• (g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally

Cookies used by our Service Providers.

6.5 Our service providers use cookies, and those cookies may be stored on your computer when you visit our website.

6.6 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Managing Cookies

6.8 Blocking all cookies will have a negative impact upon the usability of many websites.

6.9 If you block cookies, you will not be able to use all the features on our website.

7. Our Details

7.1 This website is owned and operated by Broker Insights Ltd.

7.2 We are registered in Scotland and our registered office is at 30 & 34 Reform Street, Dundee, United Kingdom, DD1 1RJ

7.3 Our principal place of business is Unit 8, Water’s Edge, Camperdown Street, Dundee, DD1 3HY.

7.4 You can contact us:

(a) by post, to the postal address given above.

(b) using our website contact form.

(c) by telephone, on the contact number published on our website.

(d) by email, using the email address published on our website.

8. Amendments

8.1 We may update this policy from time to time by publishing a new version on our website.

8.2 You should check this page occasionally to ensure that you are happy with any changes to this policy.