This privacy policy applies between you, the User of this Website and WALT & WINCHESTER FINANCIAL LIMITED, the owner and provider of this Website. WALT & WINCHESTER FINANCIAL LIMITED takes the privacy of your information very seriously. This privacy policy applies to our use of all Data collected by us or provided by you in relation to your use of the Website.
Please read this privacy policy carefully.
Definitions and interpretation
- In this privacy policy, the following definitions are used:
| Data | collectively all information that you submit to WALT & WINCHESTER FINANCIAL LIMITED via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws; |
| Data Protection Laws | any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations, and secondary legislation, for as long as the GDPR is effective in the UK; |
| GDPR | the General Data Protection Regulation (EU) 2016/679; |
| WALT & WINCHESTER FINANCIAL LIMITED, We or Us | WALT & WINCHESTER FINANCIAL LIMITED, a company incorporated in England and Wales with registered number 13543744 whose registered office is at 58 Chorley New Road, Bolton, Lancashire, BL1 4AP; |
| User or you | any third party that accesses the Website and is not either (i) employed by WALT & WINCHESTER FINANCIAL LIMITED and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to WALT & WINCHESTER FINANCIAL LIMITED and accessing the Website in connection with the provision of such services; and |
| Website | the website that you are currently using, www.waltwinchester.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions. |
- In this privacy policy, unless the context requires a different interpretation:
- the singular includes the plural and vice versa;
- references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
- a reference to a person includes firms, companies, government entities, trusts and partnerships;
- “including” is understood to mean “including without limitation”;
- reference to any statutory provision includes any modification or amendment of it;
- the headings and sub-headings do not form part of this privacy policy.
Scope of this privacy policy
- This privacy policy applies only to the actions of WALT & WINCHESTER FINANCIAL LIMITED and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
- For purposes of the applicable Data Protection Laws, WALT & WINCHESTER FINANCIAL LIMITED is the “data controller”. This means that WALT & WINCHESTER FINANCIAL LIMITED determines the purposes for which, and the manner in which, your Data is processed.
Data collected
- We may collect the following Data, which includes personal Data, from you:
- name;
- gender;
- contact Information such as email addresses and telephone numbers;
- Date of Birth (For sanction checks we require full date of birth)
- Date of Birth for under 18 (We only require month and year)
- Contact Info (we only take email and contact number(s) in the beginning),
- Marital Status?
- Employment status?
- Single or Joint Policy?
- Smoker or Non-Smoker?
- Level of Cover Required?
- Budget?
in each case, in accordance with this privacy policy.
How we collect Data
- We collect Data in the following ways:
- data is given to us by you;
- data is received from other sources; and
- data is collected automatically.
Marketing
We will only use your personal information to send you marketing messages to tell you about relevant products and services or offers that may be of interest to you if we have a valid reason to do so under data protection legislation. The two main reasons we rely on are where we have your consent, or if we have a legitimate interest to do so.
When we rely on legitimate interests, we will issue you with marketing that we think will be of interest to you. We will only do this when we believe that our legitimate interests does not override your privacy rights.
You can ask us to stop sending you marketing messages and update your choices by contacting us at any time.
Whatever you choose, you will still receive important information such as changes to your existing products.
How long we keep your personal information
We will keep your personal information for as long as you are a customer.
After you stop being a customer, we will keep your data for up to 7 years for the following reasons:
- to respond to any questions or complaints
- to show that we treated you fairly
- to maintain records according to rules that apply to us
We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected.
Data that is given to us by you
- WALT & WINCHESTER FINANCIAL LIMITED will collect your Data in a number of ways, for example:
- when you contact us through the Website, by telephone, post, e-mail or through any other means;
- when you elect to receive marketing communications from us;
- when you use our services;
- Facebook Ads, Google Ads, Instagram Ads;
in each case, in accordance with this privacy policy.
Data that is received from third parties
- WALT & WINCHESTER FINANCIAL LIMITED will receive Data about you from the following third parties where you may have consented to calls from Financial Services organisations
Data that is collected automatically
- To the extent that you access the Website, we will collect your Data automatically, for example:
- we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
Our use of Data
- Any or all the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- internal record keeping;
- improvement of our products / services;
- transmission by email of marketing materials that may be of interest to you;
- contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
in each case, in accordance with this privacy policy.
- We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
- For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
- if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
Who we share Data with?
- We will never share data with any third party without the consent of the customer
We may use and share your personal information with service suppliers and financial institutions who we partner with, for the purposes of assessing your eligibility to receive such services. This includes the insurer and reinsurer when you apply for insurance through us. The financial institutions we partner you with or refer to becomes a data controller when a policy has been issued to you and will process your personal information for their legitimate business purposes, which includes:
- Making decisions about whether to provide insurance and assistance services (such as claim assessment, claim processing, and claim settlement)
- Administering the policy, assessing, and paying claims, and general customer service activities (including complaint resolution and claims disputes)
- Detecting, investigating, and preventing crime, including fraud and money laundering
- Carrying out market research and analysis
- Providing information about your policy in connection with any reinsurance
- Complying with applicable laws and regulatory obligations (including laws and regulations outside of country of residence)
Whenever we use your information for these purposes personal data rights are considered carefully and you have a right to opt-out of some of this processing
If we sell our company or part of it, we will share your information with the purchaser, who may then provide you with information on their products and services.
We may transfer and process any personal information you provide to us to countries outside the European Economic Area. Again, we will ensure that all adequate safeguards are in place in connection with such transfer and that all necessary consent has been obtained.
Keeping Data secure
- We will use technical and organisational measures to safeguard your Data, for example:
- access to your account is controlled by a password and a user name that is unique to you.
- we store your Data on secure servers.
- Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: complaints@waltwinchester.co.uk.
- If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Data retention
- Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
- Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Your rights
- Individuals have a number of rights in connection with their Personal Information. These rights only apply in certain circumstances and are subject to certain exemptions. These rights are noted below. All enquiries in respect of these rights will be handled by WALT & WINCHESTER FINANCIAL LIMITED, however, where necessary, we will liaise with other parties with whom we have shared your personal information (“Who we share your personal information with” above) when dealing with your request. You have the following rights in relation to your Data:
- Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
- Right to erase – the right to request that we delete or remove your Data from our systems.
- Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
- Right to data portability – the right to request that we move, copy or transfer your Data.
- Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
- To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: complaints@waltwinchester.co.uk or write to Data Protection Officer, WALT & WINCHESTER FINANCIAL LIMITED, 58 Chorley New Road, Bolton, BL1 4AP.
- If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/
- It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Changes of business ownership and control
- WALT & WINCHESTER FINANCIAL LIMITED may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of WALT & WINCHESTER FINANCIAL LIMITED. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
General
- You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
- If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Changes to this privacy policy
- WALT & WINCHESTER FINANCIAL LIMITED reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.You may contact WALT & WINCHESTER FINANCIAL LIMITED by emailing at yourfriends@waltwinchester.co.uk.