Privacy Notice
SME Insurance Services Limited (SMEi) strongly believes in protecting your privacy and the confidentiality of your Personal Information. In order to explain how SMEi collects, uses and protects Personal Information, we have developed this Privacy Notice. Personal Information is any combination of information, in the possession of or likely to come into the possession of SMEi that can be used to identify, contact, or locate an individual (“Personal Information”) and will be treated in accordance with this Privacy Notice. This includes any expression of opinion about such individual. Any information which cannot be used to identify an individual (such as aggregated statistical information) is not Personal Information.
SMEi, a wholly owned subsidiary of Marsh Limited, is registered in England & Wales (No:03798294) at: 1 Tower Place West, Tower Place, London EC3R 5BU. SMEi is authorised and regulated by the Financial Conduct Authority (Firm Reference No: 306057).
This Privacy Notice covers the information practices of websites that link to this Privacy Notice (each referred to as a “Site”). The data controller of this website is SMEi.
PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
SMEi may collect, use and disclose your Personal Information (including individuals associated with you, all of whom are referred to as “you” in this Privacy Notice) in its normal course of business for the following purposes:
- Establishing and maintaining communications with you;
- Arranging insurance cover;
- Handling claims;
- Marketing and client profiling;
- Allowing our affiliated companies to notify you of certain products or services offered by our affiliated companies;
- Processing transactions through service providers;
- Sharing with associations for those clients/participants obtaining insurance coverage by being a member of the association;
- Sharing with financial institutions and other organizations where we have joint marketing agreements;
- Facilitating premium finance arrangements;
- Credit assessments and other background checks;
- Where we believe it is necessary to meet legal, security, processing and regulatory requirements;
- Protecting against fraud, suspicious or other illegal activities;
- Research and statistical analysis ; and
- Building databases for use by SMEi, its clients and insurers.
WHAT INFORMATION WE COLLECT
The information gathered by SMEi from this Site falls into two categories: (1) information voluntarily supplied by visitors to our Site and (2) tracking information gathered as visitors navigate through our Site.
Information Voluntarily Provided By You
When using this Site, you may choose to provide us with information to help us serve your needs. The Personal Information that we collect will depend on how you choose to use this Site.
- Where you request a brochure or report
If you request a brochure or report or further information from us, we require you to submit your name, e-mail address, the name of your organization, and the country in which you are based so we may send you the material you have requested, and to enable us to identify if you are an existing client of SMEi.
- Where you register with us and/or request an insurance quote
If you register with the Site, or request an insurance quote, we may ask you for your name, e-mail address, country, telephone number and the reason for your communication, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you with the quote. On the data submission form, we shall indicate by way of an asterisk, which information is optional and which information is mandatory. This information can include:
- Information you provide on applications or other forms, which may include your name, address, email address, age, personal identification numbers, credit card numbers, credit records, banking information, payment records, medical and health information, employment and income information;
- Information we acquire from and/or transfer to other persons (such as government agencies, industry associations, auditors, claims adjusters, your insurer and your employer) to verify your identity and the accuracy of the information you have provided;
- Information about you received from SMEi affiliates, insurers, other intermediaries, third party providers and others for underwriting or claims purposes (such as previous insurance and claims history) about our Clients and Participants; and
- Information we receive from consumer reporting agencies.
Any Personal Information that you provide will be used for the purpose indicated on the Site or in this Privacy Notice.
Following the quote, if you decide to proceed, we will collect Personal Information necessary to finalise the relevant quote and proceed with the transaction, such as your name, address, post code, contact telephone number, e-mail address, billing address or payment details, as relevant to the product. We will use your Personal Information to administer your policy, process claims and generally manage your relationship with us. We may pass the Personal Information you provide to others. Please see the Disclosure of Information to Others section for information on the categories of recipients of Personal Information.
- Where you submit content
Finally, if you submit content regarding any of the information that you view on our Site, we will ask for your name and e-mail address, so that, if you choose, we can update you by e-mail when others also comment on the content, and also so that we can manage the content in line with our Terms & Conditions. You should be aware that the information you provide there will be made publically available to SMEi employees and other users of the Site.
Website Navigational Information – Cookies
As you navigate the Site, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Site (such as the web pages viewed and the links clicked).
For more detailed information, please visit our Cookie Notice.
DISCLOSURE OF INFORMATION TO OTHERS
We do not disclose any Personal Information about you to any third parties except as stated in this Privacy Notice, as otherwise permitted by law, or authorised by you.
Third parties to whom we disclose your Personal Information are required by law and contractual undertakings to keep your Personal Information confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation. The purposes for which we may disclose your Personal Information to third parties are as follows:
- To conduct our business as an insurance intermediary and risk consultant including for the purposes of arranging insurance cover, handling claims, facilitating premium finance arrangements in respect of which we may disclose your Personal Information to insurers, reinsurers, intermediaries or other brokers, outsourcers, sub-contractors, agents and service providers, premium finance providers and professional advisors and auditors;
- To associations for those Clients/Participants obtaining insurance coverage by being a member of the association;
- To notify you or allow our affiliated companies to notify you of certain products or services offered by our affiliated companies; and
- To update information with credit bureaus and insurance reporting agencies.
If these third parties wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent.
Affiliate Sharing
In the normal course of performing services for our clients, Personal Information may be shared within SMEi and its affiliates for research and statistical purposes, system administration and crime prevention or detection. This may require Personal Information to be accessed or moved to a country different from the one where the Personal Information was collected. When you supply us with information containing third party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform general insurance and other services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason(s) for obtaining the Personal Information, the fact that it may be disclosed to third parties such as SMEi, and have consented to such disclosure and use.
Service Providers
As a number of the service providers (including certain SMEi affiliates) we use are located in countries outside the European Economic Area (“EEA”), including the United States, your Personal Information may be transferred to countries, which do not have as robust a data protection regime as those countries within the EEA.
The transfer of Personal Information is governed by European Union (EU) standard contractual clauses, the EU-US Privacy Shield or equivalent data transfer agreements to protect the security and confidentiality of your Personal Information.
Business Transfers
As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either SMEi itself or substantially all of SMEi assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third party purchaser in these circumstances.
Other Legally Required Disclosures
SMEi preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site if SMEi has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of SMEi, employees, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request.
In this Privacy Notice, the purposes identified above and in “Collection, Use and Disclosure of Personal Information” will be referred to as the “Identified Purposes.”
CONSENT
Your knowledge of and consent to SMEi collection, use and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:
- Your voluntary provision of Personal Information to us directly or indirectly, for example through another insurance intermediary, a representative or your employer for the purposes set out above;
- Your express consent or acknowledgement contained within a written, verbal or electronic document; and
- Your verbal consent solicited by SMEi (or our agent) for a specified purpose.
Where SMEi relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorised representative such as a legal guardian, agent or holder of a power of attorney.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. SMEi will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for SMEi to collect, use or disclose your Personal Information could mean that we cannot obtain insurance coverage or other requested products, services or information for you.
If you wish to withdraw your consent please refer to the Questions or To Withdraw Consent sections below.
However, there are a number of instances where SMEi does not require your consent to engage in the processing or disclosure of Personal Information. SMEi may not solicit your consent for the processing or transfer of Personal information for those purposes which have a statutory basis, such as:
- The transfer or processing is necessary for the performance of a contract between you and SMEi (or one of its affiliates);
- The transfer or processing is necessary for the performance of a contract, concluded in your interest, between SMEi (or one of its affiliates) and a third party;
- The transfer or processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests; or
- The transfer or processing is required by applicable law.
LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION
SMEi will collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose, and subject to your consent (where appropriate), that new purpose will become an Identified Purpose.
SMEi will collect Personal Information by fair and lawful means. We will normally retain Personal Information as long as necessary for the fulfillment of the Identified Purposes. However, some Personal Information may be retained for longer periods as required by law, contract, or auditing requirements.
SAFEGUARDS
We have in place physical, electronic and procedural safeguards appropriate to the sensitivity of the information we maintain regarding Clients and Participants. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Among such safeguards are the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties, and similar security protocols. However, due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information, and SMEi expressly disclaims any such obligation.
EXTERNAL LINKS
SMEi Sites may include links to other websites whose privacy policies we do not control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your web browser), use of any Personal Information you provide is governed by the privacy notice of the operator of the website you are visiting. That notice may differ from ours. If you can't find the privacy notice of any of these websites via a link from the website's homepage, you should contact the website directly for more information.
ACCURACY, ACCOUNTABILITY, OPENNESS AND CUSTOMER ACCESS
It is important that the Personal Information (e.g. email address) that we hold about you is accurate, complete and up-to-date. If any of your details change you can update us by e-mailing us at customer.services@smeinsurance.com. Please keep us informed of changes to your Personal Information.
You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete or incorrect. However, to secure your Personal Information, SMEi does not provide online access to its customers to view or amend Personal Information in its database.
TO WITHDRAW CONSENT
You may exercise your right to withdraw your consent to applicable uses or disclosures of your Personal Information (which may limit or terminate the products and services that SMEi provides to you) by writing to us at the above address. We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information.
Normally we will respond to access requests within 30 days.
QUESTIONS, REQUESTS OR COMPLAINTS
If you have any questions about this Privacy Notice, want to access your Personal Information or wish to make a complaint about this Privacy Notice, you can do so by writing to our Head of Compliance at the following address:
Chantrell House
The Calls
Leeds
LS2 7HA
Phone: 0330 134 4602
Email: customer.services@smeinsurance.com
A copy of this Privacy Notice (and any significant changes) can be obtained from our Web site at www.smeinsurance.com
CHANGES TO THIS PRIVACY NOTICE
The Privacy Notice is subject to change at any time. It was last changed on January 2017. If we make changes to this Privacy Notice, we will update the date it was last changed. Any changes we make to this Privacy Notice become effective immediately when we post the revised Privacy Notice on this Site. We recommend that you review this Privacy Notice regularly for changes.
