Privacy Statement

We are U K Insurance Business Solutions Limited (UKIBS) and we introduce Churchill customers to Fluro Platform Limited.

UKIBS is part of the same group of companies as U K Insurance Limited (UKI) who own the Churchill brand.

Information collected from you & cookies policy

Where we have collected information directly from you it will usually be obvious what this is, as you will have given it to us. This might not be the case where we have used cookies to collect information from your computer or portable electronic devices. Please see our cookies policy for more information.

Information collected from others

We can collect information about you from others. This includes information from:

Fluro Platform Limited. Who collect all the information needed to facilitate a quote, provide, arrange and manage your Personal Loan. We will receive information about your Loan from them.

We receive and use this information for analytical purposes as part of the contract you enter into with Fluro Platform Limited.

We and other companies within our group of companies use your personal information in the following ways:

A. To inform you about and promote products (marketing)

At the time when your personal information was collected, we asked you to indicate your marketing preferences. These preferences can be revisited at any time by contacting our Data Rights Team. Please see section 9 for contact details.

We may use your personal information to offer you suggestions about products and services you might want to buy. We may use external companies to do this on our behalf.

We can use your personal information in this way because it is in our legitimate interests to provide you with the right information at the right time, so that we may look at ways of extending our relationship that we have with you. We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to meet this legitimate interest.

Where we have a legitimate interest to do so or, where necessary you have given us your consent, we may pass your personal information to third parties including:

• • U K Insurance Limited and Green Flag Limited, both members of the same group of companies as U K Insurance Business Solutions Limited that introduces our customers to products and services. We may send you marketing from them where we believe you will have an interest in their communications and / or
• External companies such as digital content providers to display adverts about our products and services.

If you have chosen not to opt out of marketing we will send you information about our products and services by email, post, telephone or SMS unless you tell us not to. If your information has been provided to us by a third party for marketing purposes we will rely on the consent you have provided to them to conduct direct marketing.

If at any time you do not wish us to use your personal information for this purpose, you may ask us not to do so. See section 9 below for how to contact us. However, we will keep a note of your earlier marketing preferences for 6 years. We will not contact you unless you change your mind and tell us that you would like to receive marketing again.

B. To administer and improve our services

To administer our services we will share information with others (including to people or organisations that may be based overseas):

• To help develop our products, services and systems to deliver you a better sales and claims experience in the future; and
• To understand how our prospective customers make decisions about which insurance policy is the optimal policy.

We may also process your personal data to better understand you as a customer, including to determine how best to retain your custom, and to ask you to provide feedback on the service we provide to you.

We can use your personal information in this way because it is in our legitimate interests to provide the services in the most efficient way. We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to achieve this efficiency.

We may share your personal information with third parties and other companies within our group of companies for the purposes mentioned in section 3 above. A list of our group companies can be found at https://u-k-insurance.co.uk/group-companies.html. Alternatively, you can contact the Data Protection Officer for a list of them. Please see section 9.

We may send your personal information overseas to any part of the world. The protections given to your personal information in other parts of the world will often not be as strong as in the UK. Where possible, we will put in place agreements with the people we send your personal information to, to require them to treat your personal information with the same protections that we apply ourselves. Our agreements may include standard terms provided by the EU called EU Model Clauses or may require the other party to be signed up to government standards that are recognised as providing the right level of protection. But it is possible that regardless of what is set out in the agreement this would not stop a government in any part of the world from accessing your personal information, as they can often have power to overrule any agreements we make.

We are only allowed to keep your personal information if we need it for one of the reasons we describe in section 3 above.

As a general rule, we will keep it for 6 years from the date you end your relationship with us or Fluro Platform Limited for this insurance. We will also retain data in an anonymous form for statistical and analytical purposes.

If we rely on your consent to collect and process your personal information, you can ask us to stop using your personal information at any time by withdrawing that consent and we will stop using your personal information for those purposes. We may rely on your consent to tell you about products or services which may be of interest to you or to use computers to make decisions about you to improve our services or develop our products (see section 8).

At any time, you can tell us to stop using your personal information to tell you about products or services that may be of interest to you or allowing computers to make decisions about you in order to improve our services or develop our products (see section 8). To find out how to do this, see section 9.

We will collect information about you and put this into our computer systems. The computer systems will make certain automated decisions about you which will be based on comparing you with other people. This will have an impact in terms of the level of product that we offer to you or the products or services that we decide to tell you about.

This is important because in selling you other products it helps us decide which other products might be useful to you.

We also use computer systems to carry out modelling. Sometimes using your personal information and sometimes using data in anonymised form. We conduct this modelling for a variety of reasons, for example, to make decisions about how we improve and develop our products and services or to better understand how our prospective customers make decisions about which policy is the optimal policy (i.e. we are not making decisions directly about you).

Our Data Rights Team are responsible for responding to your questions about this privacy notice or your requests to exercise your rights which are set out below. The Data Rights Team may be contacted at U K Insurance Business Solutions Limited, Churchill Court, Westmoreland Road, Bromley, BR1 1DP or alternatively by email at Data.Rights.Requests@directlinegroup.co.uk.

You may contact us at the address above for one or more of the following reasons:

To ask us to correct information about you that is wrong or incomplete.

To ask us to delete personal information about you (the so-called "Right to Erasure").

To tell us you no longer agree to, that you object to, or that you wish to restrict us using information about you and ask us to stop.

To tell us to stop using your personal information to tell you about products or services that may be of interest to you (direct marketing).

A right of access, namely to ask us to provide you with a copy of all of the personal information that we have about you. A "data portability" right, namely to obtain and reuse the information that you have provided to us for your own purposes across different services. You may ask for this information to be provided directly to you or directly to another organisation. We will provide the information in a machine readable format so that another organisation's software can understand that information.

To ask us to review automated decisions made about you (as explained in section 8).

Sometimes we will not be able to stop using your personal information when you ask us to (e.g. where we need to use it because the law requires us to do so or we need to retain the information for regulatory purposes).

In other cases, if we stop using your personal information, we will not be able to provide services to you, such as administering your insurance policy or servicing your claim.

We will tell you if we are unable to comply with your request, or how your request might impact you, when you contact us.

Complaints

If you have any concerns about the way in which we are using your personal information, please contact our Data Protection Officer in the first instance at U K Insurance Business Solutions Limited, Churchill Court, Westmoreland Road, Bromley, BR1 1DP or alternatively by email at DataProtection@directlinegroup.co.uk and we will endeavour to resolve your concern. However, you do also have the right to complain about how we treat your personal information to the Information Commissioner’s Office ("ICO"). The ICO can be contacted at:

ICO website: https://ico.org.uk/global/contact-us

ICO telephone: 0303 123 1113

ICO textphone: 01625 545860