Privacy Notice

In this Privacy Notice, ‘we’, ‘us’ and ‘our’ refers to Ethos Partner Holdings Ltd and its trading styles, company registration number 10276896) and whose registered address is Hexagon House, Grimbald Crag Close, Knaresborough HG5 8PJ.

This privacy notice sets out how we collect and process your personal data, this privacy notice also provides certain information that is legally required and lists your rights in relation to your personal data.

This privacy notice relates to personal information that identifies you as a natural person (whether you are an actual or potential partner firm, an individual who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this privacy notice as personal data or personal information and further detail of what this includes are set out in this privacy notice below.

This privacy notice may vary from time to time so please check it regularly. This privacy notice was last updated on 10 June 2020.

For the purposes of relevant data protection legislation we are a controller of your personal data.

As a controller we use (or process) the personal data we hold about you in accordance with this privacy notice.

What information we hold about you and where we obtain this from

The personal data that we collect about you may include the following information:

Personal data you provide to us in person, via our website or by telephone
Personal data you provide to us when enquiring about our services or becoming a partner firm.
General information such as name, address, contact details, date of birth and financial details, such as bank account and card details. This also includes information such as criminal convictions and credit history.
Financial details such as credit history, bank details etc.
We may also collect data from others who are associated with you such as your employees or representatives such as business contact details including e-mail address used for business correspondence.
Information from publically available sources and third party databases made available to the insurance industry for the purposes of reducing fraud and financial crime as well as any other databases where your personal data may be held and processing is necessary for the fulfilment of a contract with you
Information about your use of our website such as your IP address, which is a unique number identifying your computer including personal data using cookies

How we use your personal data and the lawful basis for doing so

Where we are relying on a basis other than consent, we may rely on one or more of the following legal basis when processing your personal data for the following purposes:

How we will use your data and the lawful basis for doing so	Purposes for which we process your personal data the lawful basis on which we can do this
In order to perform our contractual obligations to you.	The processing is necessary in connection with any contract that you may enter into with us.
To continue to administer your account, including any financial transactions.	The processing is necessary in connection with the contract you have entered into with us
To assist in the prevention and reduction of fraud and other financial crime.	The processing is necessary for us to comply with the law and our legal requirements
In the interests improving our service, telephone calls you make to us may be monitored and/or recorded.	The processing is necessary to pursue our legitimate interest in the management and operation of our business.
To let you know about products and services relevant to your business which are available to you.	The processing is necessary to pursue our legitimate interest in operating our business

Special categories of data and criminal convictions

We may need to collect special categories of data from you which we will do by consent. We may also collect information on criminal convictions which we may share with third parties, the lawful basis for doing this will the necessity in connection with a contract (Article 6(b)). In addition we will also be complying with the requirements as set out in Article 10 of the regulations and the Data Protection Bill.

Who we pass your personal data to

We may need to pass your personal data to other companies which may include:

Other companies or brands within our group of companies
Insurers, intermediaries and third party service providers
Firms that provide administration and processing services to us or on our behalf under contract and to whom we have a legitimate interest in passing your data to in order to complete activities such as, IT Systems and administrative services, the development and approval of internal databases and mail processing.
Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
Other organisations that we have a duty to or are permitted to disclose your personal information to by law. For example if we received a valid request from the police or other third party organisation in the interest of preventing and detecting crime
Fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud.
Credit reference agencies to check your credit history. This check will be recorded on your credit reference file without affecting your ability to apply for credit or other financial products
Third parties we use to recover money you may owe us or to whom we may sell your debt
Another company, if our business or part of it is bought or taken over by that company to make sure your services can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over

The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the European Union. We will only do so if there are adequate levels of protection in place as required by the General Data Protection Regulations.

Accessing our Website

When you visit one of our websites we may collect information from you, such as your email address, IP address and other online identifiers. This helps us to track unique visits and monitor patterns of customer website traffic, such as who visits and why they visit. We use third parties to collate IP addresses to help us understand our Internet traffic data and data regarding your browser type and computer. We may also use web usage information to create statistical data regarding the use of our website. We may then use or disclose that statistical data to others for marketing and strategic development purposes, but no individuals will be identified in such statistical data.

We may use cookies and/or pixel tags on some pages of our website. A cookie is a small text file sent to your computer. A pixel tag is an invisible tag placed on certain pages of our website, but not on your computer. Pixel tags usually work together with cookies to help us to give you a more tailored service. We also use cookies and pixel tags in our email communication to personalise the email and track whether the email has been opened and whether the recipient has used any website links contained in the email communication. This allows us to monitor and improve our email communications and website. Useful information about cookies, including how to remove them, can be found at http://allaboutcookies.org.

Internet browsers normally accept cookies by default, although it’s possible to set a browser to reject cookies. We’ll ask your permission before using any cookie that’s not essential to the email or the use of the website. However, refusing to accept cookies may restrict your use of our website and/or delay or affect the way in which our website operates. You can find more information on Cookies when you visit our website.

The open nature of the internet is such that data may flow over networks without security measures, and may be accessed and used by people other than those for whom the data is intended. While this is outside of our control, we do take the protection of your information very seriously and aim to apply appropriate levels of security at all times.

Data Processing

There might also be situations where you may pass details of third party personal information to us to enable us to deliver the products and services to you. We only receive this data from you to carry out services on your behalf. We are therefore a Data Processor only from the purposes of receiving, processing and storing this information. The terms under which we process this information will be specified in the contract and service schedules as issued from time to time.

Your Rights

We will only store your data for as long as is necessary to comply with the requirements of your agreement and any legal obligations or lawful processing conditions that may exist as a result.

You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep your information. If this is the case, we’ll let you know our reasons.

You can ask us to:

Provide a copy of your personal information
Correct or delete unnecessary or inaccurate personal information
Restrict or to object to the use of your personal information at any time
Object to any automated decision, including profiling. (Where an automated decision has been made we will advise you of this and of your rights)
Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you
Where we may reply on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing information has been sent prior to you advising that you don’t want us to contact you again.

You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement. Further details about the ICO are available at: www.ico.org.uk

How to contact us

If you need to contact us in connection with the use or processing of your personal data, then you can do so using our contact details as set out below.

Our data protection representative is

Paul Thomas
Information Security Officer
paul.thomas@bravo-group.co.uk
Telephone 07484 908074