1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
- Collecting personal information
3.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website (including [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths]);
(b) information that you provide to us when registering with our website
(c) information that you provide when completing your profile on our website (including [your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details]);
(d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including [your name and email address]);
(e) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including [the timing, frequency and pattern of service use]);
(f) information relating to any purchases you make of our [goods and/or services] or any other transactions that you enter into through our website (including [your name, address, telephone number, email address)];
(g) information that you post to our website for publication on the internet (including [your user name, your profile pictures and the content of your posts]);
(h) information contained in or relating to any communication that you send to us or send through our website (including [the communication content and metadata associated with the communication])]; and
(i) any other personal information that you choose to send to us]
3.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
- Using personal information
4.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
4.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available on our website;
(g) send you non-marketing commercial communications;
(h) send you email notifications that you have specifically requested;
(i) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(j) send you marketing communications relating to our business [or the businesses of carefully-selected third parties] which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(l) deal with enquiries and complaints made by or about you relating to our website;
(m) keep our website secure and prevent fraud; and
(n) verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).
4.2 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
4.3 Your privacy settings can be used to limit the publication of your information on our website and can be adjusted using privacy controls on the website.
4.4 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
- Disclosing personal information
5.1 We may disclose your personal information to [any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors] insofar as reasonably necessary for the purposes set out in this policy.
5.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
5.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) [to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling]; and
(e) [to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information].
5.4 Except as provided in this policy, we will not provide your personal information to third parties.6.
- Retaining personal information
6.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Without prejudice to Section 7.2, we will usually delete personal data falling within the categories set out below at the date/time set out below:
(a) All personal data will be deleted within 12 months.
6.4 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
- Security of personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.3 All electronic financial transactions entered into through our website will be protected by encryption technology.
7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.5 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy [by email or through the private messaging system on our website].
- Your rights
9.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address)].
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing purposes.
9.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
- Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
12.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12.5 We use both session and persistent cookies on our website.
12.6 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 44) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 48), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
12.7 Blocking all cookies will have a negative impact upon the usability of many websites.
12.8 If you block cookies, you will not be able to use all the features on our website.
12.9 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 44), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 48), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
(d) Deleting cookies will have a negative impact on the usability of many websites.
- Our details
13.1 This website is owned and operated by ViiSana Limited.
13.2 We are registered in England and Wales under registration number 96677713 and our registered office is at 30-34 North Street, Hailsham, East Sussex, BN27 1DW.
13.3 Our principal place of business is at County House, 3 Shelley Road, Worthing, BN11 1TT
13.4 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
How we will handle your personal data and protect your privacy.
A guide to how we meet the requirements of the Data Protection Act (GDPR)
Making sure personal data is secure and properly dealt with is of paramount importance in our dealings with you. It is therefore important you understand what information we will take, why we need it, and how we will process your details.
What data will you ask me for?
In order to fully understand your financial needs and be able to give good advice, we need to obtain information about you, your family, your personal circumstances, and your preferences.
Some of the information will be private and may be sensitive, such as details of your income and expenditure, health, debts and credit commitments, legal proceedings and adverse credit. Much of the information you provide will, as part of your application, be passed on to the company whose products you apply for.
Do I have to provide my personal data?
In order for us to be able to give you suitable advice, we need you to provide all the information we ask for as openly and honestly as possible. If you prefer not to disclose some information, please tell us that you prefer not to disclose it and we will assess whether this will alter or impede the work we are doing for you.
How will you use my data?
There are a number of reasons we need to process your personal data;
- The primary reason is to allow us to do the job you’ve asked us to do. Specifically, we will use your data to:
- Assess and provide advice to meet your needs and circumstances;
- Introduce you to a range of product and service providers in order to meet your requirements;
- Administer cases and assist processing of applications;
- Tell you about any changes to products and service we have arranged for you;
- Inform you about products and services we think may be suitable for you (unless you ask us not to send you this information).
- We may also process your information in order to meet our legal and regulatory requirements. These may include:
- Complying with the regulations set out by the Financial Conduct Authority and other regulators as required;
- Preventing financial crimes such as money laundering and fraud by passing your details to other relevant bodies such as the police and National Crime Agency where required.
- We may also process your personal data for our own legitimate interests. Typically, these would be limited to:
- Analysing our business for trends and research how we can improve our services to customers;
- Reviewing the work we have carried out for you to ensure we have met the regulations and quality standards;
- Ensuring we are able to exercise or defend legal challenges in the future.
How long we will store your data?
We will only keep your personal information as long as necessary. How long that is depends on the type of data and the nature of the work we have carried out. In most cases, your personal data will be stored for an indefinite period as we need to keep evidence that we have fulfilled our legal and regulatory requirements.
Can I see a copy of my personal data?
Yes. Please write to our Data Controller (details below) and we will provide a copy of any personal data we hold about you within one calendar month of receiving your request. Please note that we may need to verify your identity before providing the information.
What if my data is incorrect or incomplete?
You have the right to have your data corrected or completed by contacting our Data Controller in writing (details below). Please be aware that we need to maintain records of information as it was at the time of the advice or the transaction taking place.
Can I have my data erased?
If we have provided you with advice or processed a transaction on your behalf, we will not normally be able to erase your personal data. This is because we are obliged to maintain records of our advice and transactions to meet our regulatory requirements and in case we need to exercise or defend legal claims in future.
How can I get more information?
If you would like further details on how we use your personal information or if you have any data protection queries, please write to:
The Data Protection Officer, ViiSana, County House, 3 Shelley Road, Worthing, East Sussex BN11 1TT
Telephone: 0333 7720761
*Telephone calls may be recorded and monitored for training and security purposes.
If you’d like to make a complaint about how we have handled your personal data…
…please write in the first instance to The Data Protection Officer at the above address.
If you are not satisfied with the Data Protection Officer’s response, you can make a complaint to:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Email through their website at: https://ico.org.uk/concerns/