Privacy Notice

Introduction

This Privacy Notice is designed to help you understand how we collect and use your information.

We may collect information from you about other people, for example, family members who may drive your car or who may be included on a travel or household insurance policy. If you give us information about another person it is your responsibility to ensure and confirm that:

• you have told the individual who we are and how we use personal information, as set out in this Privacy Policy; and
• you have permission from the individual to provide that personal information to us and for us to use it, as set out in this Privacy Notice.

If you have any questions or queries about this policy please contact us.

Who we are

The Active Risk Group is made up of different legal entities, details of which can be found here:

For any questions or concerns relating to this Privacy Notice or our data protection practices, or to make a subject access or any other request regarding the information we hold, please contact us at either:

Within Europe, our insurance intermediation services are offered via our sister company ARG ActiveRisk Europe GmbH

Data Protection Representative

Our Data Protection Representative for the Active Risk Group is Martin Crannis, you can contact them at: Dataenquiries@active-risk.com

Why we need and how we use your personal information

To enable us to take the necessary steps to enter into a contract with you to provide the appropriate insurance products and services we collect the following information:

• You – First Name, Surname, Address, Postcode, Date of Birth, email address, phone number.
• Other people that you want on the same Policy – Name, relationship to you, email address.
• Professional qualifications
• Work/Sports experience
• Your living situation
• Job title and Employment history
• Medical history – Any injuries, illnesses or other medical conditions that might be relevant
• Whether you or they have any unspent criminal convictions
• Whether you or they have any County Court Judgements regarding your commercial interest.
• Details and values of items you wish to insure.
• Payment details in order to purchase the insurance.
• Details of your claims history and about any claim being made under the proposed insurance.
• Details of any complaint should there be any instance that leads to a need to make one.

If you do not wish us to collect this information, we cannot offer you a Sportscover or Active Underwriting product.

Any personal information provided by you may be held by Sportscover Europe Ltd, Active Underwriting Ltd and Sportscover Australia in relation to your Sportscover/Active products or service. It may be used by our staff in making a decision concerning your Sportscover/Active product or service and for the purpose of servicing the Sportscover/Active product or providing the Sportscover/Active service, administering claims, and resolving complaints. Information may be passed to other service providers for these purposes. Information may also be passed to insurers and reinsurers, the Financial Regulator, Financial Ombudsman, HMRC, auditors and others who have a legal requirement to see it or to honour a legal obligation. We may obtain information about you from credit reference agencies, fraud prevention agencies and others to check your credit status and identity. The agencies will record our enquiries, which may be seen by other companies who make their own credit enquiries. We will check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we will record this.

We may also use generic personal information to assist us in product development and pricing. We and other organisations may use these records to:

1. help make decisions on Sportscover/Active products and any claims, for you and members of your household
2. trace debtors, recover debt, prevent fraud, and manage your Sportscover/Active product
3. check your identity to prevent money laundering unless you furnish us with satisfactory proof of identity.

Under Data Protection legislation, you can ask us in writing for a copy of certain personal records held about you.

Marketing

We may contact you by letter email or phone during the life of the Sportscover/Active product and/or the course of any claim and at the conclusion of the claim to complete any customer satisfaction surveys. We will take the following measures to ensure that personal information kept is accurate:

• We will check each new application against any existing customer records
• Where relevant, on anniversary dates or renewal dates, we will write to ask for any updates

If you have already consented and wish us to stop using your information for this purpose or any other purpose then please contact us.

Nature of personal information 

Personal data is any information that may identify a living individual. 

We collect personal information such as name, contact details, date of birth, gender, marital status, financial details, employment details and other personal details depending on the nature of the insurance and other services we offer. 

We may collect, use, and store sensitive personal information such as criminal convictions and medical conditions as necessary in relation to insurances such as motor, home, travel and health insurance. This information may be shared with insurers, insurance product providers and our third-party service providers. Where necessary, we shall obtain your consent to the processing of such information.

Sharing information

We will only supply your personal information to other parties where such a transfer is a necessary part of the activities that we undertake, where you give us consent or where we are required to do so by law or regulation (e.g., where the disclosure is necessary for the purposes of the prevention and/or detection of crime). 

As an intermediary we must disclose personal information to insurance companies, underwriting agencies, business partners and other parties in order to provide our products and services and to enable you to enter into insurance contracts. Examples of other parties include other insurance intermediaries, loss adjusters, regulatory bodies, legal and accountancy firms involved in the claims handling process. We may also share your personal information with fraud prevention agencies such as the Claims and Underwriting Exchange Register and Motor Insurance Anti-Fraud and Theft Register. We may pass information relating to your insurance policy and any incident to the operators of these registers, their agents, and suppliers. 

We may also disclose your information to service providers engaged to perform services on our behalf. Such service providers are contractually restricted from using or disclosing the information we give them except as necessary to perform services on our behalf or to comply with legal requirements. 

We only share your information if we are satisfied that our partners or suppliers have sufficient measures in place to protect your information in the same way that we do.

We may also disclose personal information to new owners of our business in the event that we are subject to a merger or acquisition. Disclosure may also be made to enable company audits, regulatory inspections or to investigate a complaint, suspicion of fraud or a security threat.

We never share your information outside our organisation for marketing purposes.

You understand that we may disclose the information you provide to relevant other parties for the purposes described in this Notice.

Transfer of personal data outside the UK

Certain personal information held on our Information Technology systems may be transferred across geographical borders in accordance with applicable law.

By providing us with your information, you consent to the collection, international transfer, storage, and processing of your information. These transfers are governed by European Union (EU) standard contractual clauses or equivalent data transfer agreements to protect the security and confidentiality of personal information.

How long do we keep your data?

We will keep your personal data for as long as is necessary for the purposes for which it was originally collected. These purposes can be found in the section ‘How will we use your information?’

To ensure the financial integrity of our records held in our databases, we will retain your personal data within those systems indefinitely unless it is deemed unlawful to do so.

Where information has been created based on the data held in those databases, for example reports, documents, and spreadsheets, it shall be kept for no longer than is necessary for the purposes for which it is being processed. Once we decide that we no longer need your information it will be securely and confidentially destroyed.

Usage analytics

Sportscover/Active collects information about how you use our website. This is done in order to drive further developments and to improve your user experience in the future.

We collect the number of views of each page or screen on the web site that you visit in order to buy a policy to enable us to determine where you got to in the sales process.

Your data protection rights

You have certain legal rights under UK data protection law and regulations, summarised as follows:

• The right to be informed about our data processing activities, including through Privacy Notices such as this.
• The right of access to the personal information we hold about you. To request a copy of this information you must make a subject access request in writing to us.
• The right of rectification. You may ask us to correct any inaccurate or incomplete data within one month.
• The right to erasure and to restrict processing. You have the right to have your personal data erased and to prevent processing except where we have a legal obligation to process your personal information. You should bear in mind that by exercising this right you may hinder or prevent our ability to provide products and services.
• The right to data portability. On your request, we will provide you with your personal data in a structured format.
• The right to object. You have particular rights in relation to automated decision making and profiling to reduce the risk that a potentially damaging decision is taken without human intervention. You can object to your personal data being used for profiling, direct marketing or research purposes.

If you want to invoke any of these rights, or withdraw your consent please write to us using the relevant postal or email address as stated in the “How to contact us” section.

Cookies

When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the Internet, this sometimes involves placing small amounts of information on your device, for example, computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally. This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission. Any cookies that may be used by this website are used either solely on a per session basis or to maintain user preferences. Cookies are not shared with any third parties. Some cookies enable Google to determine whether you are a return visitor to the site, and to track the pages that you visit during your session.

These pieces of information are used to improve services for you through, for example:

• Enabling a service to recognise your device so you don’t have to give the same information several times during one task.
• Measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they are fast.
• You can manage these small files yourself and learn more about them through Internet browser cookies – what they are and how to manage them.

Withdrawal of consent

Where you have provided your specific consent to the use of personal data, you may withdraw that consent by contacting us using the contact detail in the “How to make a complaint” section.

How to make a complaint

If you wish to make a complaint about how we hold or use your data, please contact us:

If you are dissatisfied with how we deal with your complaint, you may contact the Information Commissioner’s Office:

The Information Commissioner Wycliffe House Water Lane Wilmslow Cheshire, SK9 5AF; Phone: 08456 30 60 60 Website: www.ico.gov.uk

European Union

In the EU individuals have the right to raise any concerns about how we process your personal data to our German offices at Hoheluftchaussee 95, 20253, Hamburg or to Der Budensbeauftragte fur den Datenschutz und die Informationsfreiheit at www.bfdi.bund.de or write to them at Graurheindofrer Strasse 153, 53117, Bonn. 

We would, however, appreciate the chance to deal with your concerns before you approach the ICO or BFDI, so please contact us in the first instance.

Information from other sources

We may use legal public sources such as the electoral roll and other third party sources such as credit reference agencies to obtain information about you, for example to verify your identity or check your credit history. 

We also obtain information about you from credit reference agencies and similar third parties. Some personal information may be provided to us by third parties such as insurance companies, other insurance intermediaries and motor vehicle licensing authorities. In some cases you will have previously submitted your personal information to them and given them approval to pass this information on for certain purposes.

Such information will only be obtained from reputable sources which operate in accordance with the General Data Protection Regulation.