Privacy Policy

Your privacy is important to us. We want you to understand what we do with your data

1. Introduction

This Privacy Policy will help you understand what data we collect from you, why we collect it and what we do with it. This policy explains how we store and use your personal information when you interact with our website, or where we otherwise obtain or collect your personal information.

This Privacy Policy applies to all products and services offered by Policy Expert, except where otherwise noted. We reserve the right to change our Privacy Policy from time to time and without notice and encourage you to check regularly for any changes that may have taken place. If we decide to change our Privacy Policy, we will update the Privacy Policy page content and last modified date on our website.

Please note: If you give us personal information about other people such as joint policy holders on home insurance or additional drivers for motor insurance you must make sure they are aware of this privacy policy.

This Privacy Policy was last modified on 15th June 2020.

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2. Privacy Statement

We are committed to keeping your personal data safe and to ensuring the integrity and security of any personal data we may process.

You should read this privacy notice carefully as it contains important information on the way in which we will process your personal data, in particular:

  • Who we are and how you can contact us
  • The personal information we collect about you
  • Our legal bases for processing your personal information
  • What we do with your personal information
  • Who your personal information may be shared with
  • Your rights as a data subject under data protection legislation
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    3. Who are we?

    We are Policy Expert (which is a trading name of QMetric Group Limited). We are the controller of our customers, and prospective customers, personal data for the purposes of data protection legislation. We are committed to protecting your privacy and adhere to the relevant data protection legislation.

    Our Data Protection Officer contact details are:

    Mr Paul Gildersleeves, 110 Bishopsgate, London, EC2N 4AY.

    If you have any queries or requests concerning your personal information or how we process it, please contact us either via the Data Protection Officer or at:

    Customer Relations,

    Policy Expert Home,

    Silbury Court West,

    352-390 Silbury Boulevard,

    Milton Keynes,

    MK9 2AF

    For home insurance

    home-dpo@policyexpert.co.uk

    For motor insurance

    motor-dpo@policyexpert.co.uk

    Please note in this Privacy Policy, 'our', 'we' and 'us' refer to QMetric Group Limited, trading as Policy Expert.

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    4. Personal Information we collect or obtain about you.

    We collect personal data relating to you and your use of our services from a variety of sources. These are detailed below along with descriptions of what we do with this information.

    We collect personal data directly from you such as your name, occupation, date of birth, address, telephone number, email address, and insurance history via:

  • service data - your personal data that are provided in the course of the use of our services
  • enquiry data - information contained in any enquiry you submit to us regarding products and/or services
  • transaction data - information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website
  • notification data - information that you provide in any promotions, competitions, feedback forms
  • correspondence data - information contained in or relating to any communication that you send to us;
  • We may also obtain your personal data, which is gained indirectly or passively in the following ways:

  • usage data - information we gather from your use of, and interaction with, our website and the devices you use to access them.
  • third party data - publicly available data from third parties about you as an individual, including financial history and insurance claim information.
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    5. Our use of cookies

    If you visit the Policy Expert website, we will collect information about your online activity in a 'cookie'. A cookie is a small text file that is downloaded onto 'terminal equipment' (e.g. a computer or smartphone). It allows us to recognise the device you are using and store some information about your preferences or past actions.

    The cookies we use are non-privacy intrusive, which means they do not contain personal information that is unique to you as user of our website.

    There are cookies we use that are strictly necessary and essential for the use of our website, without these you will not be able to complete online quotes or purchases.

    We also use cookies for our legitimate business interests to improve the website experience and to analyse the number of visitors to our website.

    To see full details of all the cookies we use please visit www.policyexpert.co.uk/cookie-policy.

    Our website contains links to other websites which are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their Privacy Policy.

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    6. How we use your personal data

    We will only process your data where we have a legal basis for doing so. We use your data to communicate with you and to offer you our services and products. We will also use your data to improve or maintain the services we offer to you. We will never share your data with any other third party, other than those stated in this policy, nor use your data for any other purpose, unless we firstly gain yourconsent to do so.

    We rely on a number of legal bases for collecting and further processing your personal data. These are:

  • Contract
  • Legal Obligation
  • Legitimate Interest
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    6.1 Contract

    We collect personal information about you when you apply for products or services. We will ask you to provide some information about yourself for security, identification and verification purposes. When completing on-line forms, we will tell you how your information will be used in relation to the product or service you are applying for. 

    We may also monitor and record communications with you (such as telephone calls and emails) for quality assurance, training, fraud prevention and regulatory compliance purposes. 

    We will also collect personal data for the purposes of the performance of a contract with you, such as:

  • Preparing a transaction, such as an insurance quotation. 
  • Processing a transaction, including that with a third party (more details of the third parties we work with can be found on our website at: www.policyexpert.co.uk/trusted-partners).
  • Providing access to your policy details though your online account. 
  • Administering your policy, including handling any claims. 
  • Communicating with you about your policy. 
  • Offering renewal terms, or to inform you that we are unable to offer such terms. 
  • Carrying out automated decision making, only where this is necessary for entering into or the performance of a contract with you. 
  • Automated decision-making' is where a decision is made without human involvement, such as providing an instant insurance quotation on demand without the need of human intervention. It forms a necessary part of our quote process because it is the only practical way to process your data quickly enough to give you an immediate quote. It is your choice as to whether or not to accept the quote, meaning it does not create a contract at point of quote and a quote itself carries no detriment to you. Automated decisions do not form part of our claims or complaints processes. 

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    6.3 Legitimate Interest

    We may use your personal data for our legitimate business interests, whilst carefully considering and balancing any potential impact on you and your rights as a data subject under the relevant data protection legislation. 

    This may include processing your personal data to allow us to provide the best services and customer experience and to ensure products are relevant and tailored to your needs. We will always ensure that our legitimate interests will never override your rights and freedoms under data protection legislation. As an example, we may process your personal data for the following purposes:

  • For Direct Marketing purposes, relating to products and services that are compatible with the original purpose for which we originally gained the information. 
  • To communicate with you in relation to the product and services for which you received a quotation, including newsletters and marketing materials.
  • To communicate important updates about our products or services, which we think may be of interest to you.
  • For evidential purposes to effectively manage and maintain records of our relationships/communications with you.
  • To enhance, modify, personalise or otherwise improve our services and communications for the benefit of you.
  • To better understand how you interact with our website and content in order to enhance your customer experience.
  • To determine the effectiveness of promotional campaigns to inform marketing strategy.
  • In addition, we may perform statistical and other analysis on the personal data we collect, to help us understand and improve on how people use our products or services.

    Please note, you have the right to restrict the processing for which we rely on legitimate interest as the legal basis.

    Where we rely on legitimate interest as the legal basis for sending you direct marketing you have the right to object to this processing. You can opt-out or update your marketing preferences by contacting us at:

    For home insurance

    home-optout@policyexpert.co.uk

    or call us on 0330 0600 601

    For motor insurance

    motor-optout@policyexpert.co.uk

    or call us on 0330 0600 602

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    6.4 Special Category Data and Criminal Offences Data

    We may ask you for information about medical conditions you have (considered special category data) or criminal convictions you have received. This is lawfully processed as it is required for the performance of a contract or to take steps to enter into a contract. However, due to the sensitive nature of this type of data there are additional conditions required for processing this type of data. This data is processed as it is 'necessary for reasons of substantial public interest' as set out in data protection legislation.

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    7. Who we share your data with

    We do not sell, trade or otherwise transfer your personal information to outside parties other than necessary sharing. Necessary sharing includes governmental bodies or trusted third parties who assist us in operating our website, conducting our business or servicing you and for fraud prevention, so long as those parties agree to keep this information confidential.

    The full list of 3rd Parties we use is available on our website (www.policyexpert.co.uk/trusted-partners) and are used to help provide you with our products and services in the following ways:

  • Third parties necessarily involved in the actual or proposed transaction e.g. Insurers, for the purpose of obtaining a quotation for you or policy administration or comparing different products and services as requested by you;
  • Trusted suppliers who provide us with services necessary for the transaction or processing of your order, for example print and mailing services;
  • If you make a claim, the relevant claims administration company or department appointed by the relevant insurer;
  • Financial Conduct Authority and other regulatory or governing bodies including the Police;
  • Auditors;
  • Credit card and financial credit companies who process payments from you on our behalf;
  • If you choose to pay for your policy by instalments, the relevant premium finance company which will provide any finance. They may carry out credit, affordability, identity or anti-money laundering checks on you, potentially using third party agencies. If a check is carried out and depending what type of check it is, then a record of the search or other information may show on your credit file and might affect your credit rating;
  • Recognised centralised insurance industry applications, policy and claims checking systems, for example the Motor Insurance Anti-Fraud and Theft Register, all DVLA databases, the UK Fraud Prevention Service (CIFAS), the Employers' Liability Tracing Office (ELTO) and the Claims and Underwriting Exchange (CUE). CUE holds a record of incidents reported to insurance companies by policyholders and third-party claimants and provides validation of the information provided by you, both about yourself and about any other person named on the application, against the information held on CUE and against other databases hosted by IDSL. Insurers may use this information to consider whether to accept the risk. For details relating to information held about you on the Claims and Underwriting Exchange please visit  www.mib.org.uk/managing-insurance-data/mib-managed-services/cue-miaftr;
  • Credit reference agencies for the purpose of identity verification and fraud prevention, their search may appear on your credit report whether or not your quote proceeds but will not impact your credit history; 
  • Any party named in your policy and transactional documentation. 
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    8. Data processed outside the European Economic Area (EEA)

    Some of the third party suppliers we use may be located in countries outside of the EEA.

    For example, we use third party software suppliers such as Zendesk to process data such as your email address and other contact details to help manage our customer service. Zendesk stores this in the USA.

    When data is transferred outside of the EEA, it will be kept securely and only used for the purposes set out in this Privacy Policy. We will ensure the data has the equivalent protection as it would be if it were processed in the UK.

    This is done by requiring our prior written consent from the third party and only where that country or international organisation provides adequate safeguards, as recognised by the UK's Information Commissioner's Office (ICO) or, where an international organisation is located in the United States, that international organisation participates in and adheres to the EU-US Privacy Shield, or such other mechanism that may replace or supersede it.

    Our insurance partners are the data controllers in respect of the processing they carry out, and such processing will be subject to their own Privacy Policies. We do not have any control over whether they process your personal data outside the EEA. You should refer to their Privacy Policy for this information.

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    9. How long do we retain your personal information?

    Policy Expert will periodically review your personal information to ensure that we do not keep it for longer than is necessary and that it is being retained for the purposes it was originally gained. Personal data will be retained for the purposes specified in this Privacy Policy so long as we continue to have a legal basis for processing your data (e.g. legitimate interest or contractual purposes).

    Where we have provided you with a quote (but you have not purchased a policy), we will retain your personal data for 10 years from the date we obtained it for regulatory and fraud prevention purposes, and to allow any complaints to be managed. If you do purchase a policy, Policy Expert will retain your relevant personal data in relation to that policy for the duration of your contract and for 60 years after the contract ends. This is for the purpose of policy and claims administration, as well as general accounting and audit purposes.

    If the personal data is no longer necessary, or where we no longer have a legal basis for processing your data, we will delete or fully anonymise the data we hold on you. However, non personally identifiable data elements will be retained by us for statistical purposes. 

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    10. Confidentiality & security of your personal information

    Policy Expert do not sell, trade or otherwise transfer your personal information to outside parties other than those detailed in this Privacy Policy. Necessary sharing includes trusted third parties who assist us in operating our website, conducting our business or servicing you, and governmental bodies for fraud prevention, so long as those parties have adequate data protection measures in place that align with the requirements of the relevant data protection legislation. We ensure that we have appropriate technical and organisational controls in place to protect our business and our customers from unauthorised access or alteration to, disclosure or destruction of information we hold. In particular:

  • We always require verification and identification from you (or your authorised third parties) prior to allowing access to your account or before discussing any personal and account details. 
  • We have appropriate security measures in place relating to the collection, storage and processing of your personal data, including physical security measures, to guard against unauthorised access to systems. 
  • We restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
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    11. Your rights as a Data Subject

    As a data subject, for whom Policy Expert processes personal data, you can exercise certain rights in relation to the processing of your personal data, under data protection legislation, as detailed below.

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    11.1 Accessing your data

    You have the 'right of access' to the personal data we hold on you. This will include information on any data we may have sourced indirectly, for example from the Claims and Underwriting Exchange (CUE) database. We can also provide your personal data in a structured format (as a csv file) if required. This is referred to as you 'right to data portability' under the Data Protection legislation. 

    If you would like to receive a copy of the data we hold on your please contact us on:

    For home insurance

    home-dpo@policyexpert.co.uk

    or call us on 0330 0600 601

    or write to:

    Customer Relations,

    Policy Expert Home,

    Silbury Court West,

    352-390 Silbury Boulevard,

    Milton Keynes,

    MK9 2AF

    For motor insurance

    motor-dpo@policyexpert.co.uk

    or call us on 0330 0600 602

    or write to:

    Customer Relations,

    Policy Expert Motor,

    2 Parklands Avenue

    Maxim 3

    Eurocentral

    Motherwell

    ML1 4WQ

    We will respond to your request as soon as possible, and at the latest within one month of receiving your request.

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    11.2 Updating your data

    We aim to keep your data up to date and accurate. If you find we have incorrect information about you please let us know by contacting us at:

    For home insurance

    home-dpo@policyexpert.co.uk

    or call us on 0330 0600 601

    For motor insurance

    motor-dpo@policyexpert.co.uk

    This is referred to as you 'right to rectification' in data protection legislation.

    We cannot delete the data we hold on you until the relevant data retention period has expired, at which point your data will automatically be deleted or anonymised (see section 9 above). However, if you wish to stop receiving communications from us you can do so, see '11.4 - unsubscribe from marketing communications' below.

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    11.3 Restricting the processing of your data

    You have the right to request us to stop processing your data in certain circumstances, referred to as 'right to restriction of processing' in data protection legislation. These circumstances are:

  • You believe we have inaccurate data about you. In this case we will update your data on your request (see section 11.2 above).
  • Our retention period for storing your data has expired and we are going to delete the data, but you wish us to retain your information for legal reasons.
  • You no longer wish to receive marketing information from us. In this case you can unsubscribe from marketing (see section 11.4 below).
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    11.4 Unsubscribing from marketing communications

    You may opt-out of your personal information being processed for marketing communication purposes as defined in section 6.3, by contacting us at: 

    For home insurance

    home-optout@policyexpert.co.uk

    or call us on 0330 0600 601

    For motor insurance

    motor-optout@policyexpert.co.uk

    You can unsubscribe from ongoing email at any time by following the unsubscribe instructions at the bottom of each email.

    Please note that due to the advance preparation required for some types of communication, it may take up to 30 days for the communications to cease.

    This is referred to as your 'right to object' under data protection legislation.

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    12. Complaints

    Policy Expert will be more than happy to help you should you have any complaints about the processing of your personal data. Under data protection legislation, you have the right to lodge a complaint with the Supervisory Authority, the Information Commissioner's Office (ICO), who are the national authority responsible for the protection of personal data. A complaint can be made to the ICO via their website:  ico.org.uk, or through their helpline: 0303 123 1113

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