The data protection law in the UK changed on 25 May 2018. This privacy notice sets out your rights under the new laws.
Utmost International Group Holdings Limited is the controller and responsible for your personal data (“we”, “us” or “our” in this privacy notice). Our contact details are available in the contact section of our website.
This Site contains hyperlinks to other websites operated by other members of the Utmost Group. If you contact any of these subsidiaries, the entity you contact will be the controller of your personal data. These websites provide details as to how the latter companies hold, control and process personal data.
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.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Correspondence Data includes anything you provide to us using the contact information we have posted on our site, including your contact details such as your email address or phone number.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other information on the devices you use to access this website.
We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We collect your personal data when you email us, or any business in the Utmost Group listed in the contact section of our website.
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using functional cookies and other similar technologies.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when permitted to by the law, and in particular in order to conduct our correspondence with you or to carry out the effective management of our business and our website.
These purposes are based on our legitimate interest in carrying on our business effectively, however if you correspond with us about a contract we have with you then we may use your personal data to perform that contract. We may also use your personal data where it is necessary for us to do so in order to comply with our legal or regulatory obligations.
If we process your personal information based on consent, you have the right to withdraw that consent at any time. The opt-out methods will depend on how the consent was collected and will be explained when you give us your consent, e.g. you can change your mind using the opt-out link in any direct marketing emails sent to you, or by opting out of a mobile app service.
You will also be able to withdraw consent by contacting us directly using the details at the end of this Privacy Notice.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out above.
- Other members of the Utmost Group
- Our third-party service providers and data processors, including third parties who may administer our website or provide hosting services to us.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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 instructions.
We may share your personal data within the Utmost Group. In some cases, this will involve transferring your data outside the UK or European Economic Area (EEA).
Transfers within the Utmost group will be covered by an agreement entered into by members of the Utmost group (an intra-group agreement) which contractually obliges each group company to ensure that your Personal Information receives an adequate and consistent level of protection wherever it is transferred within the group. Our external third-party service providers may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we will take steps to ensure that your personal information is adequately protected and transferred in line with data protection law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 and they are subject to a duty of confidentiality.
We have put in place 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances we will 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.
YOUR LEGAL RIGHTS
You have a number of rights over your personal information which you can exercise free of charge by contacting us using the details at the end of this Privacy Notice.
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 could 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 you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Right To Information: You have a right to the information set out in this Privacy Notice. The most recent version of our Privacy Notice will always be accessible on our website. If we make changes to the type of personal information we collect and/or how we use it, we will inform you of the changes. We have controls in place to protect your personal information and minimise the risk of security breaches. However, should any breaches result in a high risk for you, we will inform you without undue delay.
Right to Restrict or Object: You can restrict or object to any unfair and unlawful collection or use of your personal information. You can object to any automated decision making that has a legal or similar significant impact for you and ask for the decision to be made by a person. You can withdraw consent and object to, for example direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to Correct and Update: You can ask us to correct and update personal information we hold about you.
Right to Delete and Be Forgotten: You can have your personal information deleted if it is incorrect, if it is no longer needed or has been processed unfairly or unlawfully. If you have withdrawn consent, you can ask for your personal information to be deleted. We will keep a record of your request so we know why your personal information was deleted. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to Portability: You can ask for a copy of all personal information that you gave us (including through your interactions with us), and which we hold in an automated format. You can receive this in a machine-readable format that allows you to keep it. You may also request us to send this personal information in a machine-readable format to another company. The format will depend on our ability to provide this in a secure way that protects your personal information. It is unlikely we will be able to use a copy of your personal information sent to us in this way. This is because we can only collect personal information that we need. We also need your most up to date personal information for underwriting and to comply with regulations.
Right to Access (commonly known as a “data subject access request”): You have the right to know what personal information we hold about you and to receive a copy of your personal information. This right does not allow you to access personal information about anyone else. To access your personal information please write to us or email us using the contact details at the end of this Privacy Notice. To help us respond as quickly as possible please let us know if you are only looking for copies of specific personal information.
44 Gutter Lane
London, EC2V 6BR
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.