This policy is set out as follows:
- 1. Important Information and who we are
- 2. The Data we collect about you
- 3. How is your personal data collected
- 4. How we use your personal data
- 5. Disclosures of your personal data
- 6. International Transfers
- 7. Data Security
- 8. Data Retention
- 9. Your Legal Rights
- 10. Glossary
1. Important information and who we are
Who we are
Cignpost Life is a trading style of Albany Park Limited, which is incorporated in England and Wales with the number 04296341. In respect of your personal information, Albany Park Limited is data controller and responsible for the personal information it holds about you for sales and marketing purposes.
Albany Park Limited is a subsidiary of Inchora Limited (incorporated in England & Wales with number 07890586) The Inchora family undertakes a diverse range of activities, a number of which are regulated by statute.
iptiQ Life S.A is part of the Swiss Re Group. In respect of your personal information, iptiQ Life S.A is the data controller for providing contracts of insurance for administration and claims handling purposes.
Albany Park Limited and iptiQ Life S.A. take the privacy and security of your personal information seriously and would like to assure you that your information will be properly managed and protected by the companies named above. Please read this notice carefully as it explains how Albany Park Limited and iptiQ Life S.A. and/or carefully selected third parties they work with collect and use your personal information.
When we mention “we“, “us” or “our” we are referring to Albany Park Limited and/or iptiQ.
You can ask for further information about the use of your personal information or complain about its use, by contacting the Data Protection Officers using the details below:
Contact Details
Data Protection Officer Inchora Limited Inchora House Building X92 Cody Technology Park Old Ively Road Farnborough Hampshire GU14 0LX Email dataprotection@inchora.com | Data Protection Officer iptiQ Life S.A. 30 St Mary Axe London EC3A 8EP For contracts of insurance and claims Email: DPO_Contact@iptiQ.com |
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This privacy notice was last updated on the 5th October 2022.
Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
In the course of our services we may collect the following personal data when you provide it to us:
- contact information
- identity information
- payment information
- lifestyle information
- health information
- details of any vulnerability
- product details
- profile information
- evidence of consent
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity,
Contact, by filling in online forms or by phone. This includes
personal data you provide when you:
- apply for our products or services;
- request marketing to be sent to you;
- give us some feedback
- call recordings
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.cignpostlife.co.uk/privacy/cookies/ for further details.
-
Third parties or publicly available sources. We may receive personal
data about you from various third parties and public sources as set
out below:
- Technical Data from the following parties:
(a)analytics & tracking providers some such as Google based outside the UK / EU;
- Google Tag Manager
- Google Analytics
- WordPress
- YouTube
- Inchora Session
- Hotjar
- Cubed.ai
(b)advertising networks based inside & outside the UK / EU;
- Google Adwords
- Bing Ads
- Google Display Network
- PPC Protect
- Facebook ads
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Credit Card Authorisation based inside the UK/EU.
-
Third party software and applications where you are given the choice
to share data with us:
- websites promoting protection insurance
-
From Medical practitioners
- where it’s necessary to obtain medical details for claims handling purposes and we will always request your consent to do so.
-
From identification and verification checking agencies:
- identity information
- anti-money laundering and sanction check information
4. How we use your personal data
You are applying for a Cignpost Life Policy, insured and administered by iptiQ Life S.A. Both iptiQ and Albany Park Ltd will be handling the personal information you provide to them for their respective purposes. This includes any sensitive personal data such as health information which you provide as part of the application process.
iptiQ Life S.A will only handle your personal information where you purchase a policy.
Albany Park Ltd and / or optic may use personal information for the
following purposes
The below table sets out:
- how we use your personal data
- the lawful bases upon which we collect and use your personal data
| Rationale/Reason for Processing | Lawful Basis for Processing | Third party recipients linked to that activity |
|---|---|---|
| to provide you with quotations for protection insurance products on your behalf to apply for products on your behalf | Performance of a contract | Our Parent companies |
| to assist in the administration of any products you have obtained through us | Performance of a contract | Our Parent companies |
| to manage complaints | Compliance with a legal obligation | Our Parent companies Our external solicitors |
| to manage legal claims | Legitimate interests we have a legitimate interest in protecting ourselves from breaches of legal obligations owed to us and to defend ourselves from litigation. This is needed to ensure that our legal rights and interests are managed appropriately | Our Parent companies Our external solicitors |
| to obtain feedback from you on the service you have received from us | Legitimate interests we have a legitimate interest in operating our business. This includes ensuring that the service we provide is of a satisfactory standard | External supplier(s) of software services to obtain feedback from you – Trust Pilot, Feefo |
| to retain records of any services or advice provided to you in accordance with our regulatory obligations. Call recordings maybe used. | Compliance with a legal obligation | External supplier(s) of data storage and data hosting services to retain records on our behalf Our Parent companies |
| to retain records of any services or advice provided to you by your adviser in order to defend potential legal claims or complaints | Legitimate interests we have a legitimate interest in defending ourselves from legal claims and complaints. This is needed to ensure that our legal rights and interests are managed appropriately |
External supplier(s) of data storage and data hosting services
to retain records on our behalf Our Parent companies |
| to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) | Our Parent companies Esben Business Services Knowall IT |
| to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) | Our Parent companies Advertising networks such as Facebook Google Adwords Bing Ads & Others |
| to use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Our Parent companies Analytics & tracking providers such
as: Google Tag Manager Google Analytics Wordpress Hotjar & Others |
|
to detect, prevent and investigate fraudulent applications for
products to undertake investigations into allegations of
misconduct and/or criminal offences to notify the relevant authorities of any suspicious activity following an investigation undertaken by us into allegations of misconduct and/or criminal offences | Compliance with a legal obligation. We also consider that we have a legitimate interest in protecting ourselves, other parties and the financial services industry more widely in detecting, preventing and investigating financial crime and/or misconduct |
The Financial Conduct Authority National Crime Agency (NCA) Police HMRC Our Parent companies |
| to undertake anti-money laundering, identification and verification checks, including assessment of your sanction check information (any personal data obtained for the purposes of meeting with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 will only be processed for the purposes of preventing money laundering or terrorist financing, unless the use of the data is permitted by or under another enactment other than those Regulations, or we have another lawful basis for processing it) | Compliance with a legal obligation | External supplier(s) to conduct anti-money laundering, identification and verification checks on our behalf Our Parent companies |
| to evidence satisfaction of any request made by you in accordance with your rights under data protection regulation | Compliance with a legal obligation | Information Commissioner’s Office |
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.
We may process:
health information and lifestyle information when providing quotes and
services in relation to a protection insurance product
In addition to the lawful basis for processing this information set
out in the above table, 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.
Marketing (Inchora Group Only)
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 only do so where we have obtained your
consent and then 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 email: dataprotection@inchora.com
By Post: Albany Park Finance, Inchora House, Building X92, Cody
Technology Park, Farnborough, Hampshire, GU14 0LX
In addition, you can opt out of receiving marketing at any time by
clicking the ‘unsubscribe’ link at the bottom of every
email.
Cookies
You can set your browser to refuse all or some browser cookies, or to
alert you when websites set or access cookies. If you disable or
refuse cookies, please note that some parts of this website may become
inaccessible or not function properly. For more information about the
cookies we use, please see (http://www.cignpostlife.co.uk/privacy/cookies/)
Information provided on another person
If you are submitting personal information about another person, then
you confirm that you have their consent to provide such information
and for their information to be used as set out in this notice, and
that you have provided a copy of this notice to that other person.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- external Third Parties as set out in the Glossary.
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Your personal information may be processed in countries outside of the United Kingdom (UK) / European Union (EU). Where we transfer your personal data to countries that are outside of the UK / EU we will ensure that the transfer is carried out in a compliant manner and appropriate safeguards are in place and in accordance with the relevant data protection requirements.
7. Data security
We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access
to your personal data to those employees, agents, contractors and
other third parties who have a business need to know. They will only
process your personal data on our instructions and they are subject to
a duty of confidentiality.
We have put in place procedures to deal with any suspected personal
data breach and will notify you and any applicable regulator of a
breach where we are legally required to do so.
8. Data retention
We will hold your personal data for differing periods of time depending upon the reason we have for processing it. These retention periods are set out below.
| Type of Record | Retention Period |
|---|---|
| Customer file containing a record of any services provided by us | For a period of six years following provision of services, or following termination of the policy. |
| Complaint file containing a record of any claim you have brought against us | For as long as we reasonably consider that you might legally bring an additional or repeat claim against us, or for as long as we reasonably consider that the information may be requested by the financial regulator or ombudsman. |
| Marketing lists | Once consent for marketing is received, we will use your data for marketing purposes until you opt out. We will then retain your data for a period of 6 months following the cessation of marketing activities. |
| Results of anti-money laundering, identification and verification checks, including assessment of your sanction check information | For as long as we are required/permitted to retain this personal data based upon our legal and regulatory obligations your sanction check information |
| Fraud and financial crime files |
For as long as we reasonably consider that: we are required/ permitted to retain this personal data based upon our legal and regulatory obligations they may be required in the establishment, exercise or defence of legal claims |
| Records of satisfaction of any request made by you in accordance with your rights under data protection regulation | 3 years from the date the request was satisfied |
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- request access to your personal data.
- request correction of your personal data.
- request erasure of your personal data.
- object to processing of your personal data.
- request restriction of processing your personal data.
- request transfer of your personal data.
- right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us using the contact details in section 1.
No fee usually required
You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a reasonable
fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these
circumstances.
What we may need from you
We may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal
data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you for
further information in relation to your request to speed up our
response.
Time limit to respond
We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
10. Glossary
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us using the contact details in section 1
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Third parties
Internal third parties
Other companies in the Inchora Group acting as joint controllers or
processors and who are based in the UK and provide IT and system
administration services, Accounting Services, Compliance, Marketing
and Communication Services and undertake leadership reporting.
Companies within the Swiss Re Group.
Companies within the Inchora Group, please see
http://www.cignpostlife.co.uk/privacy
for more
information.
External third parties
Service providers acting as processors based in the United Kingdom who
provide:
- IT and system administration services.
- credit reference agencies
- approved and appointed service providers, including those used to administer policies
- feedback and service references
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Your legal rights
You have the right to:
Request access
to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we
hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
