Who is Processing Your Personal Data?
Last updated: November 2018
1. Impelus EMEA Ltd (United Kingdom)(“Impelus EMEA”, “we”, ”us”, “our”) is the registered owner of this site and owns all rights, including the sites’ respective IP, copyrights and trademarks. We are registered with The Information Commissioner’s Office (ICO) in the United Kingdom under the Trading Name Impelus EMEA Ltd, with Registration Number ZA471818.
2. This policy discloses how we manage, use and protect the personal data that you provide (“you”, “your”) while using this site. Our site enables people to request quotes or information for the product or service shown or selected on this site (the “Product”). The service that our site provides is to connect people who are looking to purchase the Product with relevant providers of the Product (“Selected Companies”).
How We Protect Your Personal Data
4. Impelus EMEA is committed to protecting the data you provide us and we will seek to ensure that your personal data is handled and maintained in a secure and data-protection compliant environment at all times. We ensure policies and procedures are in place to protect the data we collect. We work within the guidelines and advice provided by the ICO and abide by the ICO’s requirements.
5. We seek to fully comply with the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Electronic EU Regulations 2011 and the EU General Data Protection Regulations (GDPR). If you wish to find out more, please visit www.ico.org.uk.
Our Purpose for Processing Your Personal Data
6. Impelus EMEA processes all personal data you provide to us in our Quotes Capital Sites web forms to:
6.1. fulfil the services (quotes, cost comparisons of different products etc.) presented to you on our Quotes Capital Sites.
6.3 where a request for quotes or information for the Product (“Quotes”) is submitted by you by completing our web form. Once we’ve received the request, we’ll connect you with one or more relevant Selected Companies. All Selected Companies we work with are bound under contractual obligation (we don’t work with any Selected Companies until we have a legal contract in place) to treat your personal data in compliance with all relevant laws. Before passing any Personal Data to them, we’ll tell them who you are, your Product requirements or preferences so they may contact you directly. Our web forms have really clear consent statements that set out the Selected Companies that will contact you, subject to your Consent.
We will only collect and process data that is relevant and limited to what is necessary in relation to the purposes stated above (in accordance with GDPR Article 5 (1), (c)).
Our Legitimization for Processing Your Personal Data
7. Our service offerings are based on delivering quality leads of individuals that have shown a genuine interest in the products on the website, which may include conducting a broad comparison assessment, providing information on different, prices or quotes from a range of a select group of Companies (selected Companies) which we have a contract with. The basis of legitimization to process your data is:
7.1. To fulfil our service offerings to you. We will only collect and process your data once you have given your clear consent, that is; by completing the web form which represents your interest in the services we are offering, proceeding by submitting your details. Before we collect, we will always inform you that your details will be passed on to selected Companies that we are contracted to represent via our service (listed in 13.);
7.2. For the fulfilment of a contract with our selected Companies; and
7.3. To communicate your data to the selected Companies in order to fulfil the service offerings to you, subject to your consent.
Collection of Your Personal Data
8. We collect your personal data when you provide your details in our Quotes Capital Site web form and/or correspond with us by phone, e-mail or otherwise. ‘Personal Data’ means the information you provide by completing the web form on this, and any of our Quotes Capital Sites, which usually includes:
note, we will never ask for specific information concerning sensitive data, such as policy numbers, account numbers, the company your policy was/is with, any financial specifics concerning your insurance or policy, bank account details and any other sensitive personal data that is not required for the purpose of processing your data under 6-7.
Use of Your Personal Data
9. We use your personal data collected via the Quotes Capital Sites to:
9.1 ·Provide you with quotes, cost comparisons via our selected Companies and the products and services they offer through our site;
9.2 ·Provide you with a more personalised service;
9.3 ·Subject to your explicit consent, that you set up at the time of registration and what personal data we hold about you, we may pass your personal data to Companies that we work with, and represent services and products for:
who may contact you by post, email, mobile, SMS for direct marketing purposes.
9.4 - We also like to work with other platforms such as Facebook, Google Adwords to reach out to you with adverts to create a customised experience, relatable to Our Products. Such platforms are used to reach out to other people who we believe may have a relevant or similar interest to the Products on our Quotes capital sites.
10. We may process your personal data ourselves or through data processors that will process data on our behalf (we retail full responsibility) for ensuring the data processor complies with this policy and all current data protection regulations).
11. We will only store your data in accordance with our Data Retention Policy. When we collect personal data, we will only use it for the purpose for which you consented to its collection, and store until the purpose for collecting it has expired to read our Policy
What we don’t do with your Personal Data
12. What we don’t do with your personal data:
12.1 Marketing to Children: We will never knowingly, purposely or deliberately collect personal data from persons under the age of 18, either for registration or for marketing purposes. Any data we can reasonably determine to belong to data subjects under the age of 18 will be deleted immediately, and all entries to our competitions voided without notice.
12.2 Undisclosed purpose: We don’t use it for any purpose (such as retargeting, commingling, allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis, and only to assess the performance and effectiveness of our advertising campaigns. We don’t transfer it (including any anonymous, aggregate or derived data) to any advertising network, advert exchange, data broker, or other advertising or monetisation-related service.
Our Selected Companies
13. Our selected Companies will contact you on the contact information you provide to assist you in order to fulfil the services offered. They will only do so subject to you submitting your personal data, which constitutes your active, explicit consent.
14. You have the right to:
To exercise any of the above rights, or you would like to simply If you would like to amend/delete the personal data you have provided to us details or contact us in relation to the above, please contact us by email us at email@example.com.
We may reserve the right to retain personal data where a reasonable expectation exists in order to fulfil an obligation, such as suppression, ie. to “block” future communications received by request of the data subject, a regulatory authority or by law. In this event, the data subject will be informed accordingly of our reliance on this expectation(s).
Your Data and our Selected Companies
The information you provide by completing the web form on our Quotes Capital Sites will be shared with the Selected Companies that we work with and provide service offerings in order to fulfill the service offering
By obtaining your consent, the selected Company may then contact you by email, telephone or post depending on the consents that you supplied us
Your Data, and our Selected Companies and Suppliers
15. Data and selected companies:
15.1 The information you provide by completing the web form on our Quotes Capital Sites will be shared with the Selected Companies that we work with and provide service offerings in order to fulfill the service offering
16. By obtaining your consent, the selected Company may then contact you by email, telephone or post depending on the consents that you supplied us.
16.1 We work with a select number of Suppliers who process data on our behalf. These include cloud storage providers, email service providers and publishers. We do not work with any supplier unless a legal contract is in place, and the necessary due diligence has been completed on the supplier, including their policies and processes to ensure the data processed on our behalf is kept confidential and safe.
17. You can unsubscribe or opt out from any communications from either Impelus EMEA (where applicable) or the selected Company at any time by emailing us at firstname.lastname@example.org.
Data Safety Outside the European Union
18. Our company data ecosystem involves systems in Australia which may store collected Data. These systems are managed by our parent entity, a publicly listed company bound by strict Australian Privacy and Data protection laws. Data may also be required to be passed on to You should be aware that some external data processors that may be based outside the European Union, whose laws provide a different standard of protection than that provided under English law. We will not release your data to a non-EU country processor without performing proper due diligence as to the standards of data protection within the specified country and proof of compliance with the standards of the UK Data Protection Act 1998 and other relevant legislation. Such requirements will be part of a formal and legally binding Data Processing Agreement.
Security and Storage of Your personal data
19. We store all data collected in an encrypted environment and only for as long as is necessary. However, despite our best efforts the Internet is not 100% secure and we cannot guarantee the security of any information you send to us via the Internet. We will not be responsible for any loss or damage you or others may suffer as a result of the loss of confidentiality of such information.
Cookies help websites remember you so things run smoothly. They let you add items to a shopping cart, and they can keep you logged in to sites where you have an account.
Cookies can also be used to collect demographic information so companies can better understand the people that use their website. Typically, they only contain two pieces of information; a site name and a unique user I.D.
Access, Rectification and Erasure of Your Personal Data
21. You may request access to, rectification and/or erasure of any personal data which we hold about you under the current Data Protection Act 1998 and the GDPR.
22. If you believe that any information, we are holding on you is incorrect or incomplete, or you would any data we may hold about you to be completely deleted, please write to or email us as soon as possible, at address below. We will promptly endeavour to correct any information found to be incorrect.
The Data Protection Officer
Impelus EMEA LTD,
Upper Mills Trading Estate,
Stonehouse, Gloucestershire, GL10 2BJ, England, UK
Tel: 01453 707400
Changes to this Policy
24. We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from the Last Updated date.