We take data protection and your privacy very seriously at OCL Digital Limited. Here’s how we handle your information
Last updated: 08/01/2019
This privacy notice aims to give you information on how OCL Digital Limited collects and processes your personal data through your use of this website, including any data you may provide when you submit our online contact form.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
- Who We Are
OCL Digital Limited, with registered company number 117860 is the data controller and responsible for your personal data (collectively referred to as “OCL Digital Limited”and/or “LifeInsuranceCover Services)”, “we”, “us” or “our” in this privacy notice.
We are a registered data controller with the Information Commissioner’s Office, registration number ZA459972.
Name: OCL Digital Limited
Email address: firstname.lastname@example.org
Postal address: 85 Great Portland Street, London, W1W 7LT
- The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name and last name.
- Contact Data includes address, email address and telephone number(s).
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Product Data includes form responses (the data entered and selected within our online contact form).
- Usage Data includes information about how you use our website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- How We Collect Your Personal Data
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
- Technical Data from analytics providers such as Google
- How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to effectively perform the service you require
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Our lawful basis for processing your general personal data:
|Legitimate interests: The processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject||Data used for the purpose of providing the introduction to an FCA authorised broker in order to provide the service requested by the data subject|
- Sharing of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in our lawful basis for the processing of your general person data:
- FCA authorised Financial Technology (FinTech) companies acting as data processors, joint data controllers or independent data controllers who provide the introduction to FCA authorised brokers by means of IT and system services which may be based on the data you have provided.
- FCA authorised insurance brokers acting as data processors, joint data controllers or independent data controllers in order to provide the services required.
- Your Legal Rights and Your Personal Data
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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.
- 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 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 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.
If you wish to exercise any of the rights set out above, please contact email@example.com for further details.
- 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.
- Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Data Transfers to Third Countries
The data we collect from you may, on occasion, be stored and/or processed at a destination outside the European Economic Area (EEA). It may also be processed by organisations operating outside the EEA who work for us or for one of our suppliers. These organisations may be engaged in the fulfilment of your request, order or reservation, and the provision of support services.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
- How to Make A Complaint
To exercise all relevant rights, queries or complaints, please contact us at firstname.lastname@example.org to discuss your concerns.
Following this, if you are still dissatisfied, you are able to contact the Information Commissioner’s Office directly at https://ico.org.uk/
- We work with Contact State
We work with Contact State in order that we can pass on your request to our partners correctly. Contact State provides lead validation services to us and our insurance provider partners and their intermediaries. Contact State receives “de-identified” data from us about your request – this means devoid of any contact information, or anything else identifying you as an individual person in the “real world”. It uses that de-identified data to help confirm your request has been submitted by a “real” human and not a robot, or automated request generator. This is done by examining a “browser fingerprint” associated with your request – it contains, for example, details of the model of device you are using, your Internet browser, and the region from which you submit your request. Contact State retains that de-identified data for its own purposes as “data controller” and uses it to help verify requests submitted through other websites.
If you do not want us to pass your de-identified data to Contact State, please contact us by emailing email@example.com. We also use Contact State to check some basic details in your submission (for example, the postcode), and to route your submission in its “raw” plain-text form to the insurance providers and intermediaries we work with. In doing this, Contact State acts as our “data processor” – it does not use the raw data for its own purposes.
You can find out more about how Contact State uses this data here – https://www.contactstate.com/legal/prospect-notice/ae15202e-7d58-4f25-9fe5-8a4e26488a7f