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: http://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
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: email@example.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.
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 firstname.lastname@example.org 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.
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 email@example.com or write to the Operations Director, KEPT Assets Limited, 12 – 20 Oxford St, Newbury RG14 1JB.
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.