The privacy and security of your information is important to COBRA London Markets Limited (“COBRA”). This notice explains who we are, the types of information we hold, how we may use it, who we may share it with and how long we keep it. It also informs you of certain rights you have regarding your personal information under the current data protection law. The terms used in this Privacy and Fair Processing Notices are based on those provided by the Information Commissioner’s Office (ICO). You can find out more about the ICO here: https://ico.org.uk.
Who we are?
COBRA London Markets Limited is the Data Controller of the information provided to us and is registered with the ICO on The Register of data controllers.
How we collect your personal information?
We collect your personal information:
- from the policyholder’s insurance advisor via email, our website, in person, in writing or over the telephone
- from credit reference agencies
- from websites
- from the policyholder’s insurers
- from databases established, for example, to prevent fraud or prevent funding terrorist activity
- personal data you provide if you subscribe to any of our mailing or newsletter services
What personal information do we collect?
- contact details such as name, email address, postal address and telephone number
- identification information such as your date of birth and driving license
- financial information such as your bank account details and card details or as a result of our credit checks
- information relevant to the policyholders insurance
- information relevant to claims
- information about the nature of your business and commercial assets
- details of bankruptcies and other financial sanctions
- information about your use of our website such as your IP address, which is a unique number identifying your computer, including personal data gathered by cookies
Special categories of data and criminal convictions:
We may also need to collect special categories of data from you, such as information about your health, in order to perform our contractual obligations to you. The lawful basis on which we can do this is that the processing is necessary for reasons of substantial public interest relating to insurance. We may also collect information on criminal convictions which we may share with third parties. The lawful basis on which we can do this is that the processing is necessary for reasons of substantial public interest relating to insurance.
How do we use your personal information?
Our legal basis for using your personal information is for legitimate interests pursued by us as an insurance broker except where such interests are overridden by your interests, rights or freedoms.
We may process your personal information:
- in order to provide, administer and manage an insurance policy and associated services for the policyholder
- where we have a legal or regulatory obligation to do so
- for reasons of substantial public interest, for example to prevent fraud and money laundering
Who do we share your personal information with?
Disclosure of your personal information will only be made where the third party has agreed to keep your information strictly confidential and shall only be used for the specific purposes for which we provide it to them.
In order to provide our services, we may share your personal information with:
- insurance or reinsurance capacity providers
- service providers associated with the insurance
- third parties to obtain information which may be used by us to make informed risk selection, pricing and underwriting decisions
- the police or law enforcement agencies
- third party service providers such as IT suppliers, auditors and lawyers
- regulatory bodies such as the Financial Ombudsman Service, Financial Conduct Authority and the Information Commissioner’s Office
- loss adjusters
- credit reference agencies
- other companies within the COBRA Group
How long do we keep records for?
Your information will not be retained for longer than is necessary. In most cases the retention period will be seven years following the expiry of the insurance contract, or our business relationship with you, unless we are required to retain the information for a longer period due to business, legal or regulatory requirements. Information relating to long term insurance products such as liability insurance will be retained for an extended period.
You are entitled:
- to a copy of the personal information we hold about you, there will not usually be a charge for dealing with the request
- to rectification of the information about you if it is incorrect
- in certain circumstances, to ask us to erase your personal information
- to request the restriction or suppression of your personal information
- to object to us processing your personal information
- to lodge a complaint to the Information Commissioner’s Office via https://ico.org.uk/concerns/handling/
Further information can be obtained by contacting:
COBRA London Markets Ltd
Address: 1 Minster Court, London EC3R 7AA
Email: [email protected]
Information Commissioner’s Office
Adderss: Wycliffe House, Water Lane, Wilmslow SK9 5AF
Telephone: 0303 123 1113