PRIVACY POLICY

This Privacy Policy applies between you, the User of this Website, and Whitehall Court Insurance Brokers Limited (“we”, “our” or “us”), the owner and provider of this Website. Whitehall Court Insurance Brokers Limited takes the privacy of Your information very seriously. We are committed to protecting Your Data and complying with Data Protection Laws. This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to Your use of the Website.

Please read this Privacy Policy carefully. It provides information about how we use Data and the rights available to you under Data Protection Laws.

This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: www.whcib.com/terms-of-use

1. DEFINITIONS AND INTERPRETATIONS

1.1. In this Privacy Policy, the following definitions are used:

Data	collectively all information that you submit to Whitehall Court Insurance Brokers Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Data Protection Laws	any applicable law relating to the processing of personal data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR	the UK General Data Protection Regulation;
Whitehall Court Insurance Brokers Limited, we, our or us	Whitehall Court Insurance Brokers Limited, a company incorporated in England and Wales with registered number 07269260 whose registered office is at 1st Floor, 37 Panton Street, Haymarket, London, SW1Y 4EA;
User or You, Your	any third party that accesses the Website and is not either (i) employed by Whitehall Court Insurance Brokers Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Whitehall Court Insurance Brokers Limited and accessing the Website in connection with the provision of such services; and
Website	the website that You are currently using, www.whcib.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

1.2. In this Privacy Policy, unless the context requires a different interpretation:
1. (a) the singular includes the plural and vice versa.
2. (b) references to sub-clauses, clauses, schedules, or appendices are to sub-clauses, clauses, schedules, or appendices of this Privacy Policy.
3. (c) a reference to a person includes firms, companies, government entities, trusts and partnerships.
4. (d) “including” is understood to mean “including without limitation”.
5. (e) reference to any statutory provision includes any modification or amendment of it.
6. (f) the headings and sub-headings do not form part of this Privacy Policy.

2. LAYERED APPROACH
1. 2.1. We use a layered approach to delivering information about data protection through:
  1. (a) A brief privacy notice in insurance policy documentation when we issue Your policy, which will refer to this more detailed Privacy Policy.
  2. (b) This Privacy Policy is accessible online.
  3. (c) The London Insurance Market Core Uses Information Notice Insurance involves the use and disclosure of Your Data by various insurance market participants such as intermediaries, brokers, insurers and reinsurers. The London Insurance Market Core Uses Information Notice sets out how Data is used within the insurance market, the core necessary personal data uses and disclosures. We recommend You review this Notice.
3. SCOPE OF THIS PRIVACY POLICY
1. 3.1 This Privacy Policy applies only to the actions of Whitehall Court Insurance Brokers Limited and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
2. 3.2 For purposes of the applicable Data Protection Laws, Whitehall Court Insurance Brokers Limited is the “data controller”. This means that Whitehall Court Insurance Brokers Limited determines the purposes for which, and the manner in which, Your Data is processed.
4. COLLECTION AND PROCESSING OF DATA
1. 4.1. We may collect and process the following Data about You:
  1. (a) information provided to us through enquiry, application or claims forms, including:
    1. (i) information such as Your name, address, job title, profession or contact details.
    2. (ii) sensitive information (e.g. details of any criminal or fraudulent behaviour or medical information) obtained either through You or third parties.
  2. (b) we may maintain records of any correspondence with You including phone records.
  3. (c) information we collect through cookies. Please see our cookies policy for further information.
    In each case, in accordance with this Privacy Policy.
5. WHY WE COLLECT DATA?
1. 5.1 We are required by Data Protection Laws to have a legitimate reason to process and use Your Data. The main purpose for processing Your Data is for the provision and performance of an insurance contract e.g. reviewing Your application, setting You up as a policyholder, administration and maintenance of Your insurance policy or in order to process a valid claim.
2. 5.2 We need contact details (name, address, telephone numbers and email addresses) to communicate with You about Your insurance requirements.
3. 5.3 We will collect information about You, Your assets and potential liabilities to assess Your insurance requirements, to approach providers for quotations, to place insurance policies in force and for the ongoing servicing and maintenance of those policies.
4. 5.4 Where appropriate, we may need to collect details to process payments from or to You such as bank account or payment card details.
5. 5.5 In the event of a claim, we may be required to obtain further Data so that the matter can be properly considered. This could include information about other parties involved in an incident or event.
  Legal bases
6. 5.6 As an insurance intermediary, we need to collect Data for a variety of reasons. The exact reasons will vary depending upon the specific circumstances. The legal bases that we rely upon are:
  1. (a) for the performance of a contract: our agreement with You to arrange insurance policies means that we must continue to use Your Data. This would include obtaining renewal terms, making changes to Your policy, submitting claims or handling any premium adjustments or claims payments.
  2. (b) insurance: Data Protection Laws make special provision for the processing of certain ‘special category’ Data, such as health or criminal conviction data, if the processing is necessary for an insurance purpose.
  3. (c) to meet a legal obligation: we are required to perform certain checks on customers, such as to confirm their identity or to ensure that there are no reasons why we should not do business with them. We may also be obliged to provide information to a court or regulatory body.
  4. (d) legitimate interests: Data Protection Laws allow us to hold or use Your Data if we have a legitimate reason to do so. For example, having arranged Your insurance, we will keep records in case any claim or potential dispute arises in the future so that we can establish the circumstances and, where appropriate, defend our position. We may also use Your contact details to promote our services. Where we rely upon this basis, we will balance our interests with Your own rights under Data Protection Laws. For example, we will maintain a policy so that we do not keep information longer than is reasonable.
  5. (e) consent: if no other legal basis applies, we may rely upon Your consent to use Your Data, for example, to send marketing materials to prospective customers.
7. ‘Special Category’ Data
  5.7 With regards to ‘special category’ Data i.e. sensitive information, we must obtain Your consent at the point of collecting Your Data (i.e. when you input Your details online or when completing a form) in order to process the Data unless an exemption for insurance purposes is applicable.
8. 5.8 In certain circumstances, if we do not have Your consent to process Your Data, it may impact upon our ability to issue You with insurance cover or to handle any claims.
9. Other Reasons for Gathering Your Data
  5.9 We may also gather Your Data for the following purposes:
  1. (a) in order to prevent, identify and investigate fraud or any activity that is in the public interest.
  2. (b) to defend ourselves against or make any legal claims.
  3. (c) where we have lawful purpose for processing Your Data e.g. for maintaining our accounts and records, gathering market intelligence in order to develop and improve our products and services. We will ensure that the processing of Your Data does not affect Your rights under applicable Data Protection Laws.
  4. (d) to comply with a legal or regulatory obligation e.g. where we are required to maintain records of any transactions with You, or for compliance with international legal and regulatory authorities.
10. Automated decision-making
  5.10. In certain circumstances we may need to process Your Data using automated decision-making by, or at the direction of, insurance or reinsurance providers. This involves assessment of the information provided to determine whether a product is offered and under what terms.
11. 5.11 5.11. Automated decision-making could limit the range of products available to You and if You disagree with the result, You have the right to request a manual assessment of the information provided. Please contact us if You require this.
12. Other Data You May Provide
  5.12. When You provide information about other individuals, such as employees or family members, You are responsible for drawing their attention to this Privacy Policy.
13. What other Data might we collect about You?
  5.13. We may obtain Your Data from other sources in relation to Your insurance policies. Examples may include previous and current insurers or brokers, loss adjustors and loss assessors. We require all such parties to comply with Data Protection Laws.
14. 5.14. If You use our Website, we collect information using ‘cookies’. Further information is contained in our Cookie Policy, which can be viewed at www.whcib.com/cookies-policy.www.whcib.com/cookies-policy.
6. HOW WE COLLECT DATA
1. 6.1. We collect Data in the following ways:
  1. (a) Data is given to us by you; and
  2. (b) Data is collected automatically.
7. DATA THAT IS GIVEN TO US BY YOU
1. 7.1. Whitehall Court Insurance Brokers Limited will collect your Data in a number of ways, for example:
  1. (a) when you contact us through the Website, by telephone, post, email or through any other means;
    In each case, in accordance with this Privacy Policy.
8. DATA THAT IS COLLECTED AUTOMATICALLY
1. 8.1. To the extent that you access the Website, we will collect your Data automatically, for example:
  1. (a) we automatically collect certain information about Your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes Your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
9. SHARING AND SAFEGUARDING
1. 9.1. All Data supplied to us is stored on secure servers and only accessed and used in line with our data protection policies and procedures. Data will only be accessed by our employees or authorised third parties who require the information for their business purposes.
2. 9.2 9.2. In the course of arranging and administration of Your insurance, there are a number of situations where Your Data will be shared with other parties. These include:
  1. (a) where we obtain quotes, amend Your policy or make a claim, we will forward information to product providers (insurers, managing agents or other intermediaries).
  2. (b) some product providers may appoint another party to administer the policy or respond to claims or complaints on their behalf.
  3. (c) where you require us to apply to pay your premium in instalments, we will share relevant information with credit providers to obtain their terms.
  4. (d) where we are required or permitted to do so by law or regulation, such as prevention of financial crime.
  5. (e) where we provide services in partnership with another party.
  6. (f) with third party service parties unrelated to insurance, such as data hosting / storage providers or technology suppliers.
  7. (g) if we undergo a reorganisation, or if some or all of our business or assets change ownership, we may transfer your Data to the successor company to ensure continuity of service.
3. 9.3. In circumstances where it is necessary to share Your Data with a third party, there are contractual agreements in place to ensure the security and confidentiality of Your Data and the information will only be used for the specific purpose for which it has been provided to them.
4. 9.4 We will use technical and organisational measures to safeguard the Data we collect. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@whcib.comi.info@whcib.com
5. 9.5. If You want detailed information from Get Safe Online on how to protect Your information and Your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
6. Our Group Companies
  9.6. We may share Your Data with our group companies, based in the UK, but only for the purposes laid out in this Privacy Policy and we will ensure the security of Your Data.
7. Authorised Third Parties
  9.7. We may also be required to allow authorised third parties, including service providers and suppliers, access to Your Data, for the purposes stated in section 2 of this Privacy Policy. Any Data sharing with third parties will follow applicable Data Protection Laws.
8. Governmental, Legal and Regulatory Authorities
  9.8 9.8. It may be necessary for us to share Your Data with financial and regulatory authorities (e.g. the Financial Ombudsman Service, the Financial Conduct Authority, the Information Commissioner’s Office) or proceedings and ensure our compliance with our regulatory and legal requirements.
9. 9.9 We are required to have certain processes in place with regards to anti-bribery and corruption, money laundering and fraud. If any criminal offence is detected or suspected, we may share data with third parties (e.g. law enforcement agencies, fraud prevention agencies, anti-money laundering agencies) in order to prevent crime or aid investigations if crime is identified.
10. 9.10 We may also access this data as part of our ‘Know Your Client’ procedures to establish the parties we are dealing with and when assessing a claim payment in order to prevent criminal offences.
10. DATA RETENTION
1. 10.1 There are a number of reasons why Whitehall Court Insurance Brokers Limited will retain Data, such as legal or statutory obligations, to process claims and to respond to any complaint or dispute. In certain cases, we are contractually bound to retain information on behalf of product providers.
2. 10.2 For most policies, we will retain records for up to seven years following expiry of the policy or termination of our services.
3. 10.3 Certain policies can be claimed against long after they have expired. We will retain records of these for longer than seven years based upon the likelihood of any claim, complaint or dispute arising.
4. 10.4 Where we have obtained your consent to hold your Data, we will retain it for as long as we have your consent, subject to the above timescales.
5. 10.5 Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.
6. 10.6 Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
11. MARKETING
1. 11.1 We would like to send you information about our products and services.
2. 11.2 We would also like to send you information about the products and services of other companies in our group which may be of interest to you.
3. 11.3 You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the Group.
4. 11.4 If you have consented to receive marketing, at any time you can request to no longer receive marketing communications, either by contacting us using the details below or by unsubscribing using the link in any marketing email.
12. YOUR RIGHTS
1. 12.1 Our Privacy Policy complies with Data Protection Laws including the UK General Data Protection Regulation. The law requires us to tell you about your rights and our obligations with regards to the processing and control of your Data, however not all of the following rights may be applicable in terms of our business dealings. You have the following rights in relation to your Data:
  1. (a) Right to be informed – you have the right to be informed about the collection and use of your Data.
  2. (b) Right of access – you have the right to access and receive a copy of your Data, and other supplementary information.
  3. (c) Right to rectification – you have the right to have your inaccurate Data rectified or completed if it is incomplete.
  4. (d) Right to erasure – you have the right to have your Data erased.
  5. (e) Right to restrict processing – you have the right to request the restriction or suppression of your Data.
  6. (f) Right to data portability – you have the right to obtain and reuse your Data for your own purposes across different services.
  7. (g) Right to object – you have the right to object to the processing of your Data in certain circumstances.
  8. (h) Rights related to automated decision-making including profiling.
2. 12.2 There are some circumstances where we may be required to restrict your rights in order to safeguard the public or our own interests.
3. 12.3 It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
4. 12.4 For further information regarding your rights, please visit the Information Commissioner’s Office’s website or click on the links provided above.
5. 12.5 To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@whcib.com.
13. LINKS TO OTHER WEBSITES
1. 13.1 This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
14. CHANGES OF BUSINESS OWNERSHIP AND CONTROL
1. 14.1 Whitehall Court Insurance Brokers Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Whitehall Court Insurance Brokers Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
2. 14.2 We may also disclose Data to a prospective purchaser of our business or any part of it.
3. 14.3 In the above instances, we will take steps with the aim of ensuring your privacy is protected.
15. GENERAL
1. 15.1. You may not transfer any of Your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe Your rights will not be affected.
2. 15.2. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.
3. 15.3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
4. 15.4. This Privacy Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
16. CHANGES TO THIS PRIVACY POLICY
1. 16.1. Whitehall Court Insurance Brokers Limited reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and You are deemed to have accepted the terms of the Privacy Policy on Your first use of the Website following the alterations
17. HOW TO CONTACT US
1. 17.1 If you have any questions regarding this Privacy Policy or how we use Data, you may contact our Data Protection Officer:
  Postal Address:
  The Data Protection Officer
  Whitehall Court Insurance Brokers Limited
  2 White Lion Court,
  Cornhill, London
  EC3V 3NP
  Alternatively, you may email us at info@whcib.com
18. YOUR RIGHT TO COMPLAIN
1. 18.1. If You are dissatisfied about the way we have handled Your Data and wish to complain, please contact the Data Protection Officer using the details above. We will aim to investigate and respond promptly and will provide a written response.
2. 18.2. If You remain dissatisfied or believe that we are not handling Your Data in compliance with the Data Protection Laws, You are entitled to raise Your complaint or report Your concern with the Information Commissioner’s Office. For more information, please visit the Information Commissioner’s Office website.

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