Bspoke Lifestyle Ltd Privacy Notice
Compass is a trading name of Bspoke Lifestyle Ltd.
Purpose of this notice
This privacy notice is relevant to anyone who uses our services, including policyholders, prospective policyholders, and any other individuals insured under a policy. We refer to these individuals as “you/your” in this notice.
We are dedicated to being transparent and this privacy notice tells you what we do with the information that we collect about you.
We process your personal data in accordance with the relevant data protection legislation. We are the joint data controller for the data that we process about you and we will not collect any information from you that we do not need for the purpose of administering your insurance policy. There may be additional data controllers, such as the Broker or Appointed Representative you purchased your insurance policy through or the insurer/s.
Contact details
We are Bspoke Lifestyle Ltd, referred to as “we/us/our” in this notice. Our data controller registration number issued by the Information Commissioner’s Officer is ZA454954. Our registered address is: 7 Pullman Court, Great Western Road, Gloucester GL1 3ND.
Anything you are not clear about
If you have any questions, or if there is anything that you are unclear about, please contact us at [email protected] and we will be happy to answer any queries you may have concerning this privacy notice or the way we process your personal data.
Why is your personal data required?
The provision of your personal data is necessary for us to administer your insurance policy and meet our contractual requirements under the policy.
If you fail to provide the data, it may mean that you are unable to exercise your contractual rights, including claiming under the policy. This would also hinder our ability to administer your insurance policy.
What information do we collect about you?
We may collect the following personal data about you:
- Your name, address and contact details, including email address, telephone number and date of birth
- Name and date of birth of any additional insured parties
- Financial information and property information
- Information about your business
- If a claim is made, we will also collect personal information about the claim from you and any relevant third parties.
Paying for your insurance in monthly instalments
We offer a number of different ways to pay for your insurance. If you choose to spread the cost and pay using a monthly direct debit, you will be entering into a credit agreement with a third party, Close Brothers Premium Finance (CBPF), who will assess your application for credit and verify your identity.
In order to assess your credit application and to prevent fraud and money laundering, CBPF may use credit scoring and automated decision-making systems. CBPF may also search and share data about you and persons financially linked to you at credit reference and fraud prevention agencies. When you apply for a credit limit you must also be able to afford and sustain the minimum monthly payments.
Google Analytics
To find out how people interact with our website, we use Google Analytics.
Google Analytics stores information about what pages you have visited, how you arrived there and how long you spend on the site. Google Analytics does not collect or store any personal information used to identify who you are such as your name or address. We do not allow Google to use or share our analytics data. For more information about Google Analytics cookies go to Google Privacy Policy.
Information collected from other sources
We may collect your personal data from others in the instance that you are a joint or additional insured we may collect information about you from the policyholder.
Special Personal Information
We have a legitimate interest to collect this data as we are required to use this information as part of your insurance quotation or insurance contract with us. We may also process the data where it is necessary for a legal obligation, or as part of the establishment or defence of a legal claim.
- We may also need to ask for details relating to the health or medical conditions
- Any unspent offences or criminal convictions of you or somebody else covered under your policy.
- We recognise that information about health and offences or criminal convictions is particularly sensitive information. We’ll ensure that we only use that information where we need to for our insurance purposes.
We also process special categories of your personal data as it is in the substantial public interest and it is necessary:
- For administering your insurance policy or
- To prevent and detect an unlawful act (e.g. fraud).
This is not an exhaustive list and in special instances, we may collect more personal data that stated above.
Why do we process your data?
We use your personal data to meet our obligations in our contract of insurance for you.
To provide insurance services
When you request to purchase an insurance policy from your Broker or Appointed Representative and they transfer the data to us, we use information about you to provide the agreed service, including if you make a claim.
To comply with our legal obligations
As part of our duties involved with providing insurance services, sometimes we are required by law to use personal data about you.
To deal with complaints
To help prevent and detect crime, for example, the prevention or detection of fraud); and to comply with a legal or regulatory obligation and/or assist our regulators (e.g. Financial Conduct Authority).
We can use your personal data in this way because we are required to do so by law.
To prevent fraud
We may share your information with other public bodies, including the police to detect and prevent fraudulent claims and/or activities.
To improve our products
To help develop our products and systems to deliver a better experience for the future.
How do we protect your data?
We take the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed and is not accessed by unauthorised individuals.
How long do we keep your data for?
As a rule, we will keep your personal data for seven years following the end of your relationship with us, as it is likely that we will need the information for regulatory reasons or to defence a claim. However, there may be exceptions where we need to keep your personal data for longer, such as where your policy contains liability cover.
Following the end of the retention period, your personal data will be securely destroyed.
Who might we share your data with?
Your personal data may be shared with the following categories of third parties:
- Within our group of companies, our agents and third parties who provide services to us
- Insurers/Reinsurers
- Claims – Third-Party Administrators
- Complaint – Third-Party Administrators
- Your Broker or Appointed Representative, other organisations, including parties they are contracted with who provide a service related to the insurance policy
- Loss Adjusters
- Regulatory Authorities
- Fraud Prevention Agencies
- Legal and Crime Prevention Agencies
- The Claims and Underwriting Exchange Register (CUE) and the Motor Insurance Anti-Fraud and Theft Register (MIAFTR), where the data is controlled by the Motor Insurers’ Bureau, and other relevant databases.
- Employer Liability Tracing Office (for commercial policies containing employer’s liability cover)
- Any additional insured parties who may communicate with us on your behalf, provided they have the necessary permission.
Do we share data outside the European Economic Area (EEA)?
There may be Some of the organisations we share information with may be located outside of the European Economic Area (“EEA”). We’ll always take steps to ensure that any transfer of information outside of Europe is carefully managed to protect your privacy rights. For more information on this please contact us.
When do we make automated decisions about you?
Our Underwriters may make automated decisions about you and the automated decision may impact the level of premium you will pay or the type of product that we can offer to you.
Your rights as a data subject
You have various rights in relation to your personal information, including the right to request access to your personal information, correct any mistakes on our records, erase or restrict records where they are no longer required, object to use of personal information based on legitimate business interests, including profiling, ask not to be subject to automated decision making if the decision produces legal or other significant effects on you, and data portability. For more details in relation to your rights, including how to exercise them, please contact us.
Please see www.ico.org.uk for further information on the above rights.
If you have a complaint or concern about how we use your personal information, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have the right to lodge a complaint with the Information Commissioner’s Office at any time.
Marketing Preferences
You can opt out of Compass marketing at any time.
If you receive marketing communications from us by email, each correspondence will contain instructions as to how you can unsubscribe from receiving future emails.
You can also opt-out of Compass marketing by post, email, or telephone using the contact details below.
Compass Marketing
7 Pullman Court
Great Western Road
Gloucester GL1 3ND
Tel: 0344 274 0277
Email: [email protected]