1. WHO WE ARE
Claim Technology Ltd (“CTL, WE/US/OUR”) are committed to protecting and respecting your privacy.
This policy (together with any privacy notice displayed on www.claimtechnology.co.uk (“our site”) or otherwise notified to you) sets out the basis on which we will process any personal data we collect from you or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation (2016/679) (“GDPR”) the data controller is Claim Technology Limited (company registration number 10744798) of 71-75 Shelton Street, Covent Garden, London W1S 4RH. We will, in processing your data, comply with the GDPR and all other data protection and privacy laws applied in England from time to time. We have notified the Information Commissioner’s Office of our data processing activities and are registered under number ZA293215.
Controlling and processing information: We are the controller of personal data used in our business for our own commercial purposes. Sometimes though, we will process personal data on behalf of another data controller – and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the GDPR. If we are processing on behalf of another data controller, that data controller will provide relevant information to you about how your data is being shared.
2. INFORMATION WE MAY COLLECT FROM OR ABOUT YOU
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We may collect and process the following data about you, either from you directly via our site or from those handling the relevant claim (who are our clients):
- Information that you provide by filling in forms on our site or other electronic means or by telephone. This includes information provided at the time of registering to use our site, subscribing to our service or requesting further services or searching for a product. We may also ask you for information when you report a problem with our site. The information you give us may, as well as other information, include your name, address, e-mail address, phone number, date of birth, national insurance number, passport details, driving licence details, claim particulars and credit card information.
- We may ask you whether you have been declared bankrupt and enquire about other related financial information.
- If you contact us, we may keep a record of that correspondence or communication.
- Details of transactions you carry out through our site, the fulfilment of your orders and any subsequent communications.
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data (whether this is required for our own billing purposes or otherwise) and the resources that you access.
To understand how we use these types of data, please see “How We Use Data About You” below.
We do not routinely collect any “special categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, and genetic and biometric data), nor do we collect any information about criminal convictions and offences. We may however need to collect data about your health or medical records in connection with a claim you wish to pursue or in which you are otherwise a party – we may collect this from you directly or from those handling the claim.
We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration and to analyse our customer base by aggregating such data into anonymised reports. This anonymised data does not identify any individual. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3. HOW WE USE DATA ABOUT YOU
We will only use your personal data when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal data in the following circumstances, relying on the basis of processing indicated:
Where we need to perform the contract we are about to enter into or have entered into with you.
- To provide you with information, products or services that you request from us (contact details).
- To carry out our obligations arising from any contracts entered into between you and us (contact details, payment information and any information relating to your claim).
Where it is necessary for our legitimate interests (or those of a third party, such as a client on whose behalf we are acting) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
- To perform our obligations under any contract with our clients (name, contact details, dates of birth, claim details, online identifiers, location data and other related information that our clients may provide).
- To ensure that content from our site is presented in the most effective manner for you and for your computer (online identifiers (including cookies), location data and other technical information).
- To provide you with information, products or services that we feel may interest you, (where you have consented to be contacted for such purposes to the extent consent is required by law) (contact details).
- To allow you to participate in interactive features of our service, when you choose to do so (online identifiers (including cookies), location data and other technical information).
- To notify you about changes to our service (contact details).
- To maintain a basic amount of information about you and your purchase history.
Where we need to comply with a legal or regulatory obligation.
- To retain basic transaction details for the purpose of tax reporting (contact details and transaction history).
Where you have consented to the processing.
- To send you direct marketing communications via email or fax (contact details). You have the right to withdraw consent to any such use at any time by contacting us.
4. OTHER USES/TYPES OF DATA
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data. We will only use your personal data for the purposes for which we collected it (or were asked to process it on behalf of one of our clients), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please contact us if you would like further details of any additional purposes of processing. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). If this happens we may have to cancel any order you have placed to buy goods and we may be unable to offer any services.
Please note that we may process your personal data without your knowledge or consent where required or permitted by law.
If you provide us with any personal data relating to relatives, partners or other individuals it is your duty to make such persons aware that their personal data may be shared with us and to provide them with appropriate information about how their personal data may be processed by us.
Protection for sensitive personal data (or “special categories of data”): Processing of sensitive personal data requires higher levels of protection. We may process sensitive personal data about an individual in the following circumstances:
- We will process information about an individual’s physical or mental health, or disability status, to manage and progress a claim involving that individual. This processing is on the basis of the individual having given explicit consent to this information being processed at the time of asking one of our clients to consider their claim.
As indicated above, we may use your data to provide you with information about services which may be of interest to you and we may contact you about these by post or telephone. If you are an existing customer, we will only contact you by electronic means with information about services similar to those which were the subject of a previous enquiry.
If you do not want us to use your data in this way, please tick the relevant box on the form. If you are a new customer, or where we permit named third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
Please note that even if you decide not to subscribe to, or to unsubscribe, from promotional email messages from CTL, we may still need to contact you with important information related to your account and/or claim.
We have put in place appropriate security measures intended to prevent your personal data from being lost or from being altered, disclosed, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions (or, where we are acting on behalf of one of our clients, on the client’s instructions) and they are subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features designed to prevent unauthorised access.
We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (or for which one of our clients provided it), including for the purposes of satisfying any legal, accounting, or reporting requirements. We will also keep a record of your name and email address on our suppression list if you request that we do not send you direct marketing. Once we no longer need the data we will securely destroy it (or, where we are processing on behalf of one of our claims handler clients, return their information to them).
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, whilst we retain claim details only for so long as legally required, we may retain certain basic details on a longer term basis to ensure we can resolve any future queries. Other enquiries and CV applications will be stored for six months after which they will be securely destroyed. Details of retention periods for different aspects of your personal data are available on request. In some circumstances you can ask us to delete your data: see below for further information.
We may sometimes anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal data to these websites.
9. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal data to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective buyer or seller of such business or assets.
- If Claim Technology Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- We may also disclose your information to third party service providers we use to
assist with claims fulfilment or otherwise to provide support services. In the vast
majority of cases we only use your personal data as a processor, acting on behalf
of one of our clients (the business handling your claim). In those circumstances
we will only share your information with other parties approved by our client or
with whom our client has asked us to share the data – we are acting on our
client’s instructions. If we are acting as a controller in our own capacity (for
example in relation to data provided by individual browsing our site or contacting
us independently) then we may share that information with the following people:
- Business partners or others who are a part of providing your products and services or operating our business;
- Other organisations and businesses who provide services to us such as back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office administrative functions
- Marketing organizations to monitor and improve online presence
We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our (or our client’s) instructions.
10. WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Any online payment transactions will be encrypted and carried out through our appointed agent through a secure site. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site on a secure basis, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
11. YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as summarised below.
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (of our own or of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com. We aim to respond to all legitimate requests within one month (and if we are only processing the data in question on behalf of another party, the response may actually come from that other party as the relevant data controller). Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive - alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.