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- How we use your information
- What information do we gather?
- Providing data about other people
- People who contact us
- Use of data processors
- Your rights
- Sharing information with third parties
- What websites do we use to capture information?
- Changes to this privacy notice
- How to contact us
How we use your informationTo enable us to provide the services we have agreed and for other related purposes – including updating and enhancing customer records, analysis for management purposes and statutory returns, crime prevention and legal & regulatory compliance – we may obtain, use, process and disclose personal data about you. We may collect and process the following data about you:
- Information that you provide by filing in forms on one of our websites.
- Information that you provide to us by telephone, e-mail or face to face.
- Where no advice has been provided we will hold data for no more than 12 months;
- Where advice has been provided (whether cover applied for or not) we will retain this data, to evidence this advice, but will not use this information for marketing without your consent
- If you contact us, we may keep a copy of that correspondence.
What information do we gather?Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data:
- Personal information such as name, date of birth, marital status and children; this is collected, processed and stored in order to assess needs for insurance and make suitable recommendations.
- Financial information such as assets, liabilities and income; this is collected, processed and stored in order to assess needs for insurance and make suitable recommendations.
- Medical information including some details about family medical history; this is collected, processed and stored in order to assess needs for insurance and make suitable recommendations.
- Contact details such as address, telephone number and email address; this is collected, processed and stored in order to keep clients up to date and service their policies.
- Direct debit details; this is collected, processed and stored in order to process payments for insurance contracts and satisfy anti money laundering prevention regulations.
- Non personal data such as IP address, web browser type, operating system and a list of URLs starting with a referring site, your activity on our site, and the site you exit to;
- Tracking and statistical purposes.
- Storing the information you enter to allow us to provide you with a quotation for the product you requested.
- Remembering some of the user’s details as to save them time if/when they return to the site at a later date or request a quote for a different product.
|Website*||Cookie description||Cookie name||What is it for?||Cookie lifetime|
|1, 2, 3, 4||Google analytics||__utma||Used to distinguish users and sessions||2 Years|
|1, 2, 3, 4||Google analytics||__utmb||Used to determine new sessions/visits||30 minutes|
|1, 2, 3, 4||Google analytics||__utmc||Determine whether the user was in a new session/visit||When session ends|
|1, 2, 3, 4||Google analytics||__utmt||Used to throttle request rate||10 minutes|
|1, 2, 3, 4||Google analytics||__utmz||Stores the traffic source or campaign that explains how the user reached us||6 Months|
|5||Google analytics||_ga||Used to distinguish users||2 Years|
|5||Google analytics||_gid||Used to distinguish users||24 Hours|
|5||Google analytics||_gat||Used to throttle request rate||1 minute|
|2, 3, 4, 5||Cookie Control||civicAllowCookies||Tracking if visor has seen the cookie pop-up||3 Months|
|1||Feefo tracking||sentisum_session||Tracking for feefo review system||2 Weeks|
|1||Visitor identifier||SRBsession[0-9]||Tracks and remembers information about the visitor||When session ends|
|2, 3, 4, 5||Visitor identifier||PHPSESSID||Tracks and remembers information about the visitor||When session ends|
|1||Visitor identifier||SRBreferral_id||Tracks and remembers any referral information||When session ends|
|1||Visitor identifier||SRBl_page||Tracks and remembers landing page||When session ends|
|1||AddThis social sharing site||__atuvc, __atuvs||Updates share count||2 Years|
|1||Recite Me||Recite.Persist, Recite_Session||Remembers whether the Recite Me toolbar should persist between pages or not and remembers user settings||When session ends|
People who contact usPeople who contact us via social media We use a third-party provider, SmarterQueue to manage some of our social media interactions. If you send us a private or direct message via social media the message may be stored by SmarterQueue or by the relevant social media platform. It will not be shared with any other organisations. People who contact us via SMS We use a third-party provider, TextMarketer to send/receive SMS messages. If you send an SMS message it may be stored by TextMarketer. It will then be securely stored by us against your file. It will not be shared with any other organisations. People who email us Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law. People who make a complaint to us When we receive a complaint from a person we build a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. We usually have to disclose details of the complaint to our professional Indemnity Insurance Broker and Insurer. We may be required to provide a copy of our file to the Financial Ombudsman Service, should an adjudicator be required to consider the complaint case. We are required to disclose to The Financial Conduct Authority (FCA) high level analytics concerning the number and nature of complaints received. This data does not include names or details that identify the specific data subject. We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained indefinitely. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle. People who use our services Cura Financial Services provide a range of Financial Services to Data Subjects. We process data provided by the data subject and other sources in order to deliver the appropriate products and services to Data Subjects. We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested protection advice to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.
Use of data processorsData processors are third parties who provide elements of our service for 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 it. 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. Our Data processors / Third parties that we use include:
- Regulatory and Compliance opinion where required: The Right DA Club
- IT Services: Thomas Marriot T/A Thomas Marriot IT Services
- Sanctions and PEPs checking (Anti Money laundering): Veriphy Ltd
- Research Software Tools: IRESS Portal Limited, Synaptic Software, UnderwriteMe Limited, CI Expert
- Backup Solutions: CrashPlan (Code 42 Software Inc)
- Email relay: Postmark (Wildbit, LLC)
- Newsletter Software: MadMimi
- SMS Services: TextMarketer (Esendex Ltd)
- Review Services: Feefo
Your rightsUnder the Data Protection Act 1998, you have rights as an individual which you can exercise in relation to the information we hold about you. From 25 May 2018 the General Data Protection Regulations (GDPR) come into force. Access to personal information (Portability) Data Subjects may submit a Subject Access Request – in order to obtain a copy of the personal data that we hold about them in a structured and portable manner. All SAR requests should be sent to us in writing. Confirmation of whether, and where, the controller is processing their personal data Cura Financial Services is the Data Controller and a Processor. Cura Financial Services undertakes data processing within the EEA. Right of Data subjects to erasure (Right to be forgotten) Data Subjects may notify Cura Financial Services if they wish to exercise their right to erasure. Such a withdrawal of Consent does not affect the lawfulness of processing based on consent prior to the withdrawal. Data Subjects that exercise this right will be removed from any marketing or future contact. Cura Financial Services may retain a copy of any personal data and be retained by the Controller if the processing is necessary for the establishment, exercise or defence of legal claims. Right of rectification Cura Financial Services will seek to ensure that inaccurate or incomplete data will be rectified. Data Subjects have the right of rectification. Right to object to processing for the purposes of Direct Marketing Data Subjects may notify the Firm if they wish to exercise their right to be removed from any Direct Marketing activities. Cura Financial Services may still contact the Data Subject in order to fulfill any contractual obligations concerning the policies and services provided.
Sharing information with third partiesWe may share your information with third party service providers such as insurance providers, compliance, and other agents relevant to the business activity. We will not however share your information with any third parties for marketing purposes without your consent.
What websites do we use to capture information?We use the following websites to capture initial quote information, some of these sites will provide quotes online others will refer for an adviser to contact first:
Changes to this privacy noticeWe keep our privacy notice under regular review. This privacy notice was last updated on 15th January 2019.
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