Privacy Policy

DATA PRIVACY POLICY
Introduction
We take your privacy very seriously and we ask that you read this
privacy notice carefully as it contains important information on
who we are, how and why we collect, store, use and share
personal data, your rights in relation to your personal data and on
how to contact us and supervisory authorities in the event you
have a complaint.
How we use your personal data

Full details may be found in our Privacy Statement on our website
at: www.keptassets.com

Who we are
KEPT Assets Limited collects, uses and is responsible for certain
personal data about you. When we do so we are required to
comply with data protection regulation and we are responsible as
a data controller of that personal data for the purposes of those
laws.
Special category data
Certain types of personal data are considered more sensitive and
so are subject to additional levels of protection under data
protection legislation. These are known as ‘special categories of
data’ and include data concerning your health, racial or ethnic
origin, genetic data and sexual orientation. Data relating to
criminal convictions or offences is also subject to additional levels
of protection.
KEPT Assets Limited is a company registered in England and
Wales under company number 11312742 whose principal trading
office is at 12 – 20 Oxford St, Newbury RG14 1JB.
When we mention “KEPT”, “we”, “us” or “our” we are referring to
KEPT Assets Limited.
We may process:
 Health information and lifestyle information when
providing intermediary services in relation to a
protection insurance product; and/or]
 Criminal conviction or offence information when
providing intermediary services in relation to a general
insurance product
In addition to the lawful basis for processing this information set
out above, we will be processing it either (i) for the purpose of
advising on, arranging or administering an insurance contract or
(ii) for the establishment, exercise or defence of legal claims.
In the course of our activities relating to the prevention,
detection and investigation of financial crime, we may process
criminal conviction or offence information. Where we do so, in
addition to the lawful basis for processing this information , we
will be processing it for the purpose of compliance with
regulatory requirements relating to unlawful acts and dishonesty.
The personal data we collect and use
In the course of providing our service to you we may collect the
following personal data when you provide it to us:
• Contact information
• Identity information
• Financial information
• Employment status
• Lifestyle information
• Health information
• Data about criminal convictions or offences
• Details of any vulnerability
 Details of your dependents and/or beneficiaries under
a policy.
• If you are providing information about another person
we expect you to ensure that they know you are doing
so and are content with their information being
provided to us. You might find it helpful to show them
this privacy notice and if they have any concerns
please contact us in one of the ways described below.
• Product details
Marketing
We may use personal data we hold about you to help us identify,
tailor and provide you with details of products and services from
us that may be of interest to you. We will do so in accordance
with any marketing preferences you have provided to us.
In addition, where you provided your consent, we may provide
you with details of products and services of third parties where
they may be of interest to you.
You can opt out of receiving marketing at any time. If you wish to
amend your marketing preferences please contact us:
By phone: 01635 896097
By email: contact@keptassets.com
By post: KEPT Assets Limited, 12 – 20 Oxford St, Newbury RG14 1JB.
Information collected from other sources
We also obtain personal data from other sources in the course of
providing our intermediary services. Where we obtain this
information from another party it is their responsibility to make
sure they explain that they will be sharing personal data with us
and, where necessary, ask permission before sharing information
with us.
The personal data we obtain from other sources may include the
following:
• From lenders and/or product providers:
– product details
• From identification and verification checking agencies:
– identity information
sanction check information
Whether information has to be provided by
you, and if so why
We will tell you if providing some personal data is optional,
including if we ask for your consent to process it. In all other
cases you must provide your personal data in order for us to
provide you with intermediary services.
We can continue to use your personal data following a request
for restriction where we have your consent to use it; or we need
to use it to establish, exercise or defend legal claims, or we need
to use it to protect the rights of another individual or a company.
Your rights
You have legal rights under data protection regulation in relation
to your personal data. These are set out under the below
headings:
 To access personal data
 To correct / erase personal data
 To restrict how we use personal data
 To object to how we use personal data
 To ask us to transfer personal data to another organisation
 To object to automated decisions
 To find out more about how we use personal data
To object to use of personal data
You can object to any use of your personal data which we have
justified on the basis of our legitimate interest, if you believe your
fundamental rights and freedoms to data protection outweigh
our legitimate interest in using the information. If you raise an
objection, we may continue to use the personal data if we can
demonstrate that we have compelling legitimate interests to use
the information.
We may ask you for proof of identity when making a request to
exercise any of these rights. We do this to ensure we only
disclose information or change your details where we know we
are dealing with the right individual.
We will not ask for a fee, unless we think your request is
unfounded, repetitive or excessive. Where a fee is necessary, we
will inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may
however take us longer if the request is particularly complicated
or you have made several requests. We will always let you know
if we think a response will take longer than one month. To speed
up our response, we may ask you to provide more detail about
what you want to receive or are concerned about.
We may not always be able to fully address your request, for
example if it would impact the duty of confidentiality we owe to
others, or if we are otherwise legally entitled to deal with the
request in a different way.
To access personal data
You can ask us to confirm whether or not we have and are using
your personal data. You can also ask to get a copy of your
personal data from us and for information on how we process it.
To rectify / erase personal data
You can ask that we rectify any information about you which is
incorrect. We will be happy to rectify such information but would
need to verify the accuracy of the information first.
You can ask that we erase your personal data if you think we no
longer need to use it for the purpose we collected it from you.
You can also ask that we erase your personal data if you have
either withdrawn your consent to us using your information (if
we originally asked for your consent to use your information), or
exercised your right to object to further legitimate use of your
information, or where we have used it unlawfully or where we
are subject to a legal obligation to erase your personal data.
We may not always be able to comply with your request, for
example where we need to keep using your personal data in
order to comply with our legal obligation or where we need to
use your personal data to establish, exercise or defend legal
claims.
To restrict our use of personal data
You can ask that we restrict our use of your personal data in
certain circumstances, for example
 where you think the information is inaccurate and we need
to verify it;
 where our use of your personal data is not lawful but you do
not want us to erase it;
 where the information is no longer required for the purposes
for which it was collected but we need it to establish,
exercise or defend legal claims; or
 where you have objected to our use of your personal data
but we still need to verify if we have overriding grounds to
use it.
To request a transfer of personal data
You can ask us to provide your personal data to you in a
structured, commonly used, machine-readable format, or you can
ask to have it transferred directly to another data controller (e.g.
another company).
You may only exercise this right where we use your personal data
in order to perform a contract with you, or where we asked for
your consent to use your personal data. This right does not apply
to any personal data which we hold or process outside
automated means.
If you would like to exercise any of your rights, please:
 email or write to our Operations Director at
callum@keptassets.com or KEPT Assets Limited, 12 – 20 Oxford St, Newbury RG14 1JB
 let us have enough information to identify you, e.g. name,
address, date of birth
 let us have proof of your identity and address (a copy of your
driving licence or passport and a recent utility or credit card
bill); and
 let us know the information to which your request relates.
How long your personal data will be kept
We retain personal information we collect from you where we
have an ongoing legitimate need to do so: for example:
 to provide you with a product or service you have
requested us to provide,
 to perform our contractual obligations to you;
 to comply with applicable legal, tax or accounting
requirements;
 to defend or manage any claims or complaints between
us, you and any relevant third party including taking
legal advice in respect of such claims in order to
establish, exercise or defend our legal rights or such
claims. This would include complaints and claims which
you may bring against us or which are submitted to a
court, regulatory authority or ombudsman.
When we have no ongoing legitimate need to process your
personal information, we will either delete or anonymise it or, if
this is not possible (for example, because your personal
information has been stored in backup archives), then we will
securely store your personal information and isolate it from any
further processing until deletion is possible.
Keeping your personal data secure
We have appropriate security measures in place to prevent
personal data from being accidentally lost, or used or accessed in
an unauthorised way. We limit access to your personal data to
those who have a genuine business need to know it. Those
processing your information will do so only in an authorised
manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data
security breach. We will notify you and any applicable regulator
of a suspected data security breach where we are legally required
to do so.
Privacy policy
You can find full details of our Privacy Policy on our website at:
www.dawnslater.co.uk
Your right to complain
On the rare occasions where you believe your data has been
wrongfully processed stored or handled, you have the right to
raise a concern with the Information Commissioner’s Office (ICO).
It has enforcement powers and can investigate compliance with
data protection regulation (www.ico.org.uk)
We ask that you please attempt to resolve any issues with us
before the ICO.
How to contact us
Please email or write to our Operations Director if you have any
questions about this privacy notice or the information we hold
about you.
Email callum@keptassets.com or write to the Operations
Director, KEPT Assets Limited, 12 – 20 Oxford St, Newbury RG14 1JB.
Communications
We would like to continue to communicate with you by email and
post. We will always treat your personal details with the utmost
respect and never share them with other organisations for
marketing purposes.