This privacy policy informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services as well as within our online offer and the web sites, functions and contents connected with (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in with the UK`s Data Protection ACT 2018 (DPA), the General Data Protection Regulation (GDPR)
Person responsible
Insurance Nerd a trading name of
BA Financial Services Ltd
132 – 134 Great Ancoats St
Manchester
M4 6DE
UK
Web: www. bafinancial.co.uk
Email: info@bafinancial.co.uk
Phone: 03333 442 171
FCA Register number: 930813
ICO Registration number ZB197026
Types of data processed
Inventory data (e.g., personal master data, names or addresses).
Contact data (e.g., e-mail, telephone numbers).
Content data (e.g., text entries, messages).
Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users”).
Purpose of the processing
- Provision of the online offer, its functions and contents.
- Responding to contact requests and communicating with users.
- Security measures.
Terminology used
- “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
- Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal basis
In accordance with Article 13 of the GDPR, we inform you of the legal basis for our data processing activities. For users from the area of application of the DPA and GDPR, i.e., the UK, the EU and the EEC, the following applies, unless the legal basis is stated:
- The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;
- The legal basis for processing for the fulfilment of our services and implementation of contractual measures as well as answering enquiries is Art. 6 (1) lit. b GDPR;
- The legal basis for processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c GDPR;
- In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) GDPR serves as the legal basis.
- The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Article 6(1)(e) GDPR.
- The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f GDPR.
- The processing of data for purposes other than those for which it was collected is determined by the requirements of Art. 6 (4) GDPR.
- The processing of special categories of data (in accordance with Art. 9 (1) GDPR) is governed by the provisions of Art. 9 (2) GDPR.
Contractual services
We process the data of our contractual partners and interested parties as well as other clients, customers, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 Para. 1 lit. b. GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.
The data processed includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contractual data (e.g., services used, contents of the contract, contractual communication, names of contact persons) and financial data.
As a matter of principle, we do not process special categories of personal data, unless they are part of a commissioned or contractual processing.
We process data that is required for the justification and fulfilment of contractual services and point out the necessity of their disclosure, unless this is obvious to the contractual partners. Disclosure to external persons or companies only takes place if it is necessary in the context of a contract. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client as well as the legal requirements.
When using our online services, we may store the IP address and the time of the respective user action. This storage is based on our legitimate interests as well as the interests of users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims pursuant to Art. 6 Para. 1 lit. f. GDPR or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. GDPR.
The deletion of the data takes place when the data is no longer required for the fulfilment of contractual or legal duties of care as well as for dealing with any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; in all other respects, the legal retention obligations apply.
Business analyses and market research
In order to run our business economically and to be able to recognise market trends, wishes of contractual partners and users, we analyse the data we have on business transactions, contracts, enquiries, etc. We process inventory data, communication data and market research data. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, to optimise our offer and to improve business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised values.
If these analyses or profiles are personal, they are deleted or anonymised when the user terminates the contract, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general tendency analyses are prepared anonymously, if possible.
Contacting
When contacting us (e.g. by contact form, e-mail, telephone), the user’s details are used to process the contact enquiry and handle it in accordance with Art. 6 Para. 1 lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other enquiries) GDPR. The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable system.
We delete the enquiries if they are no longer necessary.
Security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, disclosure, ensuring availability and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account in the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the performance of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis that complies with the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the UK, the EU, the European Economic Area (EEA)) or do so in the context of using third-party services or disclosing or transferring data to other persons or companies, this will only be done if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests.
Subject to legal or contractual permissions, we will only process or allow data to be processed in a third country if the legal requirements are met. This means, for example, that the processing is carried out on the basis of special guarantees or compliance with officially recognised special contractual obligations.
Rights of data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
You have the right, in accordance with the law, to request that data relating to you be completed or that inaccurate data relating to you be corrected.
You have the right, in accordance with the law, to request that data concerning you be deleted immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
You have the right to demand that the data concerning you that you have provided to us be received in accordance with the legal requirements and to demand that it be transferred to other persons responsible.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with the law.
Right of withdrawal
You have the right to revoke any consent you have given with effect for the future.
Right of objection
You may object to the future processing of data relating to you at any time in accordance with the legal requirements. In particular, you may object to processing for direct marketing purposes.
Cookies
Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. In general, we have refrained from using analytical cookies. However, may use necessary cookies for wish no consent needs to be obtained and have explained this in our cookie policy.
A general objection to the use of cookies used for online marketing purposes can be declared, via the US-American site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/.
Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
Changes and updates to the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.