1.2 You should read this policy in full. The key points covered here are:
- Where we collect and process your personal data
- Details of how we use your data
- Information on the valid circumstances we may share your data
- The controls we offer you over your personal data
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
1.3 Lightblue Online (company registration number OC355038) is an Appointed Representative of Lightblue UK Ltd which is Authorised and Regulated by the Financial Conduct Authority. Lightblue UK Ltd is registered in England and Wales, company registration number 5228731.
1.4 Lightblue Online LLP (“We”) are the data controller and will process your personal data in accordance with the General Data Protection Regulations as appropriate as well as any national laws which relate to the processing of personal data (“data protection legislation”).
2. WHERE WE GET YOUR INFORMATION?
2.1 VISITORS TO OUR WEBSITES
We may collect and process personal information about you in the following circumstances:
2.1.1 when you complete the online contact forms on our website lightblueonline.com or www.incomeprotectioncomparison.co.uk (“Sites”) providing us with basic information such as your name, email address and contact number,
2.1.2 whenever you provide information to us when reporting a problem with our Sites, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence,
2.1.3 when you visit any of our Sites we will retain details such as traffic data, location data, weblogs and other communication data, and the resources that you access.
We may also collect and process technical data which does not identify any individual in the following ways:
2.1.4 information about your device, including where available your Internet Protocol (IP) address, for reasons of fraud protection. We may also collect information about your device’s operating system and platform, browser type and version, time zone setting, and browser plug-in types and versions,
2.1.5 information about your visit, including the full Site Uniform Resource Locators (URL) clickstream to, through and from our Sites (including date and time),
2.1.6 products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
We may use data collected through our Sites for our legitimate interests in order to:
2.1.7 respond to an enquiry submitted via our online contact forms,
2.1.8 ensure that content from our Sites are presented in the most effective manner for you and for your device,
2.1.9 to administer our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes,
2.1.10 improve our Sites and services to ensure that content is presented in the most effective manner for you and for your computer,
2.1.11 process and deal with any complaints or enquiries made by you,
2.1.12 as part of our efforts to keep our Sites safe and secure,
2.1.13 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you where you have signed up for these (see section 9 for further details).
2.1.14 our Sites may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. Please check before you submit your information to these websites,
2.2 THIRD PARTY WEBSITES
2.2.1 We may collect and process personal data about you when you complete an online contact form on a third party’s website who then pass your information, with your explicit consent, on to us.
2.3 DIRECT CONTACT
2.3.1 We may collect and process personal data about you when you telephone or email our office or engage in face-face contact with us.
2.3.2 To ensure we carry out your instructions accurately, to help us continually improve our service and in the interest of security, we record and may monitor your telephone communications with us.
3.1 You may give us information about you by filling in forms on our, or third-party, websites or by corresponding with us by phone, e-mail or otherwise.
3.2 We will collect details such as; name, address, email address, contact number, date of birth, health and financial information only to provide insurance services to our customers. We do not retain any bank details.
3.3 We will share customer personal information with our employees to manage our relationship with our customers.
3.4 We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us and ask you to pass the privacy information to them.
4.1 We will collect details such as contact names, address, email address and telephone number to contact you about goods and/or services we have ordered from you, to comply with our contractual obligations and to place further orders. We may share your personal data with our employees to manage our relationship with you and we will keep your personal data for as long as we require your goods and/or services subject to a maximum of 6 years from the date of our last contact with you. We will not transfer your personal data outside the EEA.
5. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
5.1 In accordance with data protection legislation we are required to notify you of the legal basis upon which we process your personal data. We process your personal data for the following reasons:
5.1.1 For the performance, and ongoing management (which includes problem handling and complaints), of a service you consent to us providing,
5.1.2 With our parent company Lightblue UK Ltd in regard to their oversight and general management of the Lightblue Online LLP business,
5.1.3 Where necessary for compliance with a legal obligation we are subject to,
5.1.4 For our legitimate interests (as described within this policy).
6. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
6.1 We may disclose your personal data to third parties for the following legitimate business purposes:
6.1.1 We will share customer personal information with insurance providers whom will need this to assist us in the provision of protection policies that meet your specific needs and circumstances,
6.1.2 With an employee of our parent company Lightblue UK Ltd, with your consent, for them to provide you a service they can offer which Lightblue Online LLP cannot,
6.1.3 IT software providers that host our website and store data on our behalf,
6.1.4 To a prospective buyer of some or all of our business or assets, in which case personal data including your Data will also be one of the transferred assets.
6.2 We may disclose your personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.3 We will not sell or distribute your personal data to other organisations without your approval.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
7.1 During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
7.2 We’re also subject to regulatory requirements to retain your data for three years for insurance and mortgage business. This are minimum periods, during which we have a legal obligation to retain your records.
7.3 We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so. This will be for compliance purposes such as to resolve disagreements, stop fraud and abuse, prove that you had an account with us or follow our legal obligations, or the police may need it as evidence.
7.4 Other than for reasons described in section 7.3, we will not keep your personal data for longer than six years after our relationship with you has ended.
8. CROSS-BORDER DATA TRANSFERS
8.1 We do not transfer personal data outside the EEA. Where this is required in the future, we will ensure that safeguards are in place so that such transfers comply with data protection legislation.
9. DATA SECURITY
9.1 Information you provide to us is stored on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.
9.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted from our Sites; any transmission is at your own risk.
9.3 Email communications are not secure and for this reason Lightblue Online LLP cannot guarantee the security of the email, its content or that it remains virus free once sent.
10.1 We may use customer personal information to provide you with details about our or our parent company’s (Lightblue UK Ltd) services, products, business updates and events which we think may be of interest.
10.2 You have the right to opt-out of receiving this information at any time. To opt-out of receiving such information you can email us at; email@example.com or call 01702 719625 providing us with your name and contact details.
10.3 Where you have subscribed to receive marketing correspondence from us we will keep your personal data until you unsubscribe from receiving such correspondence from us.
11. ACCESS TO, UPDATING, DELETING AND RESTRICTING USE OF YOUR DATA
11.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.
11.2 Data protection legislation gives you certain rights in relation to your personal data. You have the right to object to the processing of your personal data in certain circumstances and to withdraw your consent to the processing of your personal data where this has been provided.
11.3 You can also ask us to undertake the following:
11.3.1 Update or amend your personal data if you feel this is inaccurate
11.3.2 Remove your personal data from our database entirely
11.3.3 Send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract
11.3.4 Restrict the use of your personal data
11.4 We may request specific information from you to help us confirm your identity. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
11.5 Please send any requests relating to the above to our Privacy Officer at Lightblue Online LLP by Email on: mdennison@LightblueUK.com, by phone on; 01702 719625, or by post to; M Dennison, 4 Southbourne Grove, Westcliff-on-Sea, Essex, SS0 9UR, specifying your name and the action you would like us to undertake.
12. RIGHT TO WITHDRAW CONSENT
12.1 Where you have provided your consent to the collection, processing and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please contact us at Lightblue Online LLP by Email at firstname.lastname@example.org or call 01702 719625, or by post to; Lightblue Online LLP, 4 Southbourne Grove, Westcliff-on-Sea, Essex, SS0 9UR.
12.2 For reasons described in section 7 we may have to keep some of your data even though you’ve withdrawn consent to process your data. In each case, the length of time that we need to keep the information may be different, but we will only keep the information for as long as we need it.
14. CONTACT US
15. What can you do if you are unhappy with how your personal data is processed?
15.1 You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office