Privacy Notice.

This privacy notice explains how we use any personal information we collect about you.

What information do we collect about you?

We collect and use personal information about you so that we can provide you with a policy that suits your needs whether it’s for insurance or financial advice. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.

As well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy. If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns
please contact us.

Why do we need to collect and use your personal data?

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations. Where special category data is required we will obtain your explicit consent in order to collect and process this information.

If we need your consent to use special category data, we will make this clear to you when you complete an application. If you give us consent to use this data, you are free to withdraw consent at any time by contacting us. Please note that if consent to use information is withdrawn we may not be able to continue to provide the policy and we may need to cancel the policy.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage us. We also do this to meet any applicable legal or regulatory obligations, to meet compliance requirements with our regulators (e.g. Financial Conduct Authority), to comply with law enforcement and to manage claims. We may also need to use personal information to carry out anti-money laundering checks.

Who might we share your information with?

If you agree, we may email you about our other products and services that we think may be of interest to you.

We will not share your information for marketing purposes with third parties. In order to deliver our services to you effectively we may send your details to third parties such as those that we engage with
when arranging insurance policies (e.g. insurance companies) or when arranging financial products (e.g. product and platform providers). Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your
details to third party agencies for identity verification purposes.

How long do we keep hold of your information?

In principle, your personal data should not be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim or complaint against us or to carry out relevant fraud checks, or where we are required to do so for legal or regulatory purposes. In any case, we will not retain your personal data for longer than twenty years after your policy
ends (for general insurance policies) and fifty years after your policy ends (for financial services policies). You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our
regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have various rights in relation to your personal information, including the right to request access to your personal information, correct any mistakes on our records, erase or restrict records where they are no longer required, object to use of personal information based on legitimate business interests and data portability.

If you would like a copy of some or all of your personal information please write to us using our address noted below.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Automated decision making

The firm does not carry out automated decision making to decide whether we can provide you with a product or service. We may use an automated underwriting engine to provide on-line quotes, using the information we have collected from you but we will make the final decision ourselves.

We take various measures to ensure the security of your data.

We do not use any special category data (such as data about your health) in the process unless it is strictly necessary to
deliver our service and we have obtained your explicit consent to do so.

Credit Searches

To ensure that we have the necessary facts to assess your needs, verify your identity, help prevent fraud and provide you with our best premium and payment options, we may need to obtain information relating to you at quotation, renewal and in certain circumstances where policy amendments are requested.

We may:

* undertake checks against publicly available information (such as electoral roll, county court judgments, bankruptcy orders or repossession(s)). Similar checks may be made when assessing claims,

* carry out a credit search from a credit reference agency (CRA) which will appear on your credit report and be
visible to other credit providers. It will be clear that this is a credit search rather than a credit application.


We would like to send you information about our products and services which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us using the address details below.

On-line information

When you visit our website, we may use cookies to track visitor use of the website and to compile statistical reports on website activity.

This information is used to note your interest in our website and to improve customer journeys.

Collecting this data helps us understand what you are looking for from the company, enabling us to deliver improved products and services.

Specifically, we may use data:

* For our own internal records.
* To improve the products and services we provide.
* To contact you in response to a specific enquiry.
* If you consent, we may send you promotional mailings
or to call you about any of our products and services, which we think might be relevant to you.

Cookies and how we use them

A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website.

Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to gather information such as how many people use the website and what pages they tend to visit.

How we use cookies

We may use cookies to:

* Analyse our web traffic using an analytics package. Aggregated usage data helps us improve the website structure, design, content and functions.

* Store information about your preferences. The website can then present you with information you will find more relevant and interesting.

* Recognise when you return to our website. We may show you relevant content, or provide functionality you used previously.

Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.

Controlling cookies

You can use your web browser’s cookie settings to determine how our website uses cookies. If you do not want our website to store cookies on your computer or device, you should set your web browser to refuse cookies.

However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.

Unless you have changed your browser to refuse cookies, our website will issue cookies when you visit it.

What can you do if you are unhappy with how your personal data is processed?

You have a right to lodge a complaint with the supervisory
authority for data protection. In the UK this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
0303 123 1113 (local rate)

Changes to our privacy policy

We keep our privacy policy under regular review. This privacy policy was last updated on 25/05/2018.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you by writing to us at:

Compliance Manager,
Keegan & Pennykid (Insurance Brokers) Ltd,
50 Queen Street,
EH2 3NS.
Tel: 0131 225 6005