Privacy Notice
At Simon Winter Marine we take your privacy seriously, this Privacy Notice explains how we use any personal information we collect about you.
Introduction – what is GDPR?
The way we handle your personal information is changing. General Data Protection Regulation, known as GDPR, is the new legislation that governs how we use and protect your personal information. GDPR comes into force 25th May 2018 and replaces the existing Data Protection Act or DPA. Further information on the GDPR may be found at the Information Commissioner’s Office website.
How the law protects you
Data protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside of Simon Winter Marine. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you
- When it is our legal duty
- When it is in our legitimate interest
- When you consent to it.
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
What information do we collect from you?
We will collect information about you if you contact us for insurance, this will include (non-sensitive) personal information such as your name, address, contact details, date of birth, occupation and sometimes medical records. We will also collect insurance product relevant information including details of any claims you may have made. We may also collect (sensitive) personal information such as information about your physical or mental health and details of your criminal convictions.
The information may be collected face to face (directly from you), by telephone, post, email or when you voluntarily complete the Quotation Request or Contact Us pages on our website, via proposal forms, claim forms, general enquiry cards, direct debit forms and credit agreements for example when financing your premium using our premium finance facility or when paying for your insurance using debit or credit cards. We may also collect your personal information from publicly available sources including but not limited to publications, internet search engines, social networks and from third parties including government databases.
Why do we collect this information?
The information we collect about you may be used in a number of ways, for example:
- To negotiate, arrange and administer insurance quotations, insurance policies and insurance claims
- To arrange credit agreements when financing your premium using premium finance
- For sharing with credit reference agencies for use in credit decision
- For fraud and/or money-laundering prevention
Under data protection laws, for each purpose we must be able to rely on a legal ground to justify why we are using your (non-sensitive) personal information. The legal grounds that we may rely on are:
- Performance of our contract with you
- Compliance with a legal obligation
- Legitimate interests
When we use your (sensitive) personal information (for example about your criminal convictions or health) we must be able to rely on an additional legal ground. The additional legal grounds that we may rely on in these instances are:
- Your explicit consent (you may withdraw this consent at any time by contacting us, if you do so you may not be able to receive the benefit of some of our services where in order to provide them we rely on your explicit consent to process your (sensitive) personal information)
- For legal claims
- You have made this information public
Who might we share your information with?
If you contact us for insurance we will pass your details to an insurer, underwriter, underwriting agent or insurance broker. Your information may be shared with, or obtained by, credit reference agencies or fraud prevention agencies. If you need to make a claim we will share your information with our agents and/or advisers in order to process the claim.
We may also disclose your personal information to other third parties where:
- The disclosure is required by law or by a regulator with authority over us or you, such as where there is a court order, statutory obligation or Financial Conduct Authority request; and
- We believe such disclosure is necessary in order to assist in the prevention or detection of any criminal action (including fraud) or is otherwise in the overriding public interest.
We will not share your information for marketing purposes with companies outside of Simon Winter Marine.
Marketing
We would like to send you information on other insurance products which may be of interest to you.
The personal information we have for you is made up of what you tell us, data we collect when you use our services and data we collect from publicly available sources. We study this to form a view on what we think you may want or need, or what may be of interest to you.
We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest. That is when we have a business or commercial reason to use your information. It must not go unfairly against what is right and best for you.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click here to update your preferences or by clicking ‘unsubscribe’ on any marketing email you receive from us.
We will not share your information for marketing purposes with companies outside of Simon Winter Marine.
How long do you retain my information?
If we have arranged an insurance policy for you and the policy is cancelled we will usually retain your information for up to ten years. We hold this information in order to comply with file reviews, to respond to any questions or complaints, to show that we treated you fairly, to maintain records according to rules that apply to us and if the insurances are required again.
We may keep your information for longer than ten years if we cannot delete it for legal, regulatory or technical reasons. Generally after seven years your information stored on hard copy paper files are destroyed although information is retained in digital format on our systems.
Sending data outside of the EEA
We only send your data outside of the European Economic Area (“EEA”) to:
- Follow your instructions
- Comply with a legal duty
- Work with insurers, agents and advisers who we use to help provide our products and services
If we transfer your personal information outside of the EEA we will ensure an adequate level of protection is in place to protect your personal information such as:
- Transferring to a non-EEA country with privacy laws that give the same protection as the EEA
- Putting in place contractual protections that ensures the security of any information passed
How can I access or correct the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address Simon Winter Marine Limited, Overmass House, 6B Beer Road, Seaton, Devon EX12 2PA United Kingdom. We will not make a charge for this service.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
How can I withdraw my consent?
You can withdraw your consent at any time, please click here to update your preferences.
If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.
How can I make a complaint?
If you are not satisfied with our use of your personal information, our response to an exercise of your rights set out above, or if you believe us to be in breach of our data protection obligations, you have the right to complain to the Information Commissioner’s Office, find out on their website how to report a concern.
Other websites
Our website contains links to other websites. This privacy notice only applies to this website so when you link to other websites you should read their own privacy notices or policies.
Changes to our privacy notice
We keep our privacy notice under regular review and we will place any updates on this web page. This privacy notice was last updated on 9th March 2018.
How to contact us
Please contact us if you have any questions about our privacy notice or information we hold about you:
- By email; or
- Write to us at Simon Winter Marine Limited, 6B Beer Road, Seaton, Devon EX24 6QL, United Kingdom.
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