Sprout.ai Privacy Policy

Sprout.ai | Privacy Policy V2.1.docx

At Sprout.ai we respect your privacy and we are committed to protecting your personal data. This Privacy Policy is provided in accordance with Sprout.ai’s obligations under applicable privacy and data protection law, including UK GDPR. For the purposes of this Privacy Policy, the term ‘personal data’ means any information which identifies you, or which allows you to be identified, when combined with other information. It does not include data where the identity has been removed (anonymous data).

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how, as a company we collect and process your personal data when you use our internal or external website, including our web-dashboard. Please read the following carefully together with any other privacy policy or fair processing policies we may provide on specific occasions when we are collecting or processing personal data, such as your name and email address when entered onto a contact form on our website or to fulfil our contractual obligations, i.e; to provide our services, news and information about our services and related products.

This privacy policy supplements other notices and privacy policies and is not intended to override them.

Our website is not intended for children and we do not knowingly collect data relating to children.

Controller

Sprout.ai LTD registered with the Information Commissioner’s Oce (“ICO”) in the UK under registration number ZA504194 is the controller and responsible for your personal data (collectively referred to as “Sprout.ai”, “we”, “us” or “our” in this privacy policy).

Data Protection Officer

Our Data Protection Ocer is iSTORM Intelligent Solutions Ltd who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact the DPO at DPO@istormsolutions.co.uk.

Contact details: If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Intelligent STORM Solutions Ltd

Email address: DPO@istormsolutions.co.uk

Postal address: 10 John Street, Stratford Upon Avon CV37 6UB

Telephone number: +44 (0)1789 608708

You have the right to make a complaint at any time to the 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.

GENERAL DATA PROTECTION REGULATION (GDPR) – EUROPEAN REPRESENTATIVE

According to Article 27 of the General Data Protection Regulation (GDPR), Sprout.ai has appointed European Data Protection Oce (EDPO) as its GDPR Representative in the EU.

You can contact EDPO regarding matters on the GDPR:
-by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
-by writing to EDPO at 12/14 Rond-point des Champs Elysées, Paris, 75008, France

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 dierent kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, VIN number, national insurance number.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account, payment card details, policy payment data.
• Transaction Data includes details about payments to and from you and other transactional details about insurance policies.
• 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 technology on the devices you use to access this website.
• Profile Data includes your username and password, policy details, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Claims Data includes the nature and circumstances of a claim, amount claimed, results of claims, correspondence history, supporting information for claims and associated photographic information and evidence.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

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 policy.

We may collect 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). We may also collect information about criminal convictions and oences.

If you fail to provide personal data.

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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you, including through:

Direct interactions

You may give us Identity, Contact, Financial, and Transaction Data by filling in forms / sending emails to us / our Sprout.ai website (our site) or by providing information to us for processing (our system) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, or complete a feedback survey, and when you report a problem with our site. It also includes any personal data you may provide to a third party on behalf of whom we process your data for.

This is stored in our systems. We will also look to retain any information provided to us in relation to alleged fraudsters.

Automated technologies or interactions

With regard to each of your visits to our site or system we will automatically collect Technical Data, about your equipment, browsing, actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following ways:

• Legal obligation: Where we need to process the personal data to comply with a legal obligation.
• Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Cookies

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Our cookie bar on our website allows you to accept all or deny all cookies as well as allowing for user preferences to be made on the use of cookies beyond essential.

What is a cookie?

Cookies are small text files that are placed on your computer by websites that you visit. Cookies are used to remember your settings when you revisit a website and to identify how visitors navigate the site. Cookies provide valuable information to website owners to adapt and make changes to the site in order to improve the user experience.

Why do we use cookies?

• Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
• Measure engagement and site statistics to understand how our services are used and enhance the quality of those services.

We do not use the information captured for any other purpose.

How do I control what cookies are used?

Sprout.ai | Privacy Policy V2.1.docx

You can change your cookie preferences at any time by customising your preferences when entering our website.

Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out more about how to manage cookies on the Information Commissioner’s Office website.

You can opt out of being tracked by Google Analytics across all websites by visiting this page on Google.

Change of purpose

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

Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table above. Selected third parties include:

• subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;

There are certain third parties we work with to help us to deliver you the best service we can. In order to achieve this, we use a number of third party tools which are carefully chosen to assist us in providing the best service we can.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Sprout.ai 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.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, and other agreements; or to protect the rights, property, or safety of Sprout.ai, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

The lawful basis for the third party processing will include:

• Their own legitimate business interests in processing your personal data, in most cases to prevent fraud;
• Consent;
• satisfaction of their contractual obligations to us as both a data controller and data processor;
• for the purpose of a contract in place or in contemplation;
• to fulfil our legal obligations.

Where we store and process your personal data

The data that we collect from you will be stored within the EEA.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests. Accordingly, we regularly review our use of data with the aim of removing data that we no longer have a legitimate business interest in maintaining.

YOUR LEGAL RIGHTS (please contact info@sprout.ai for any requests or questions regarding your data)

• 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 information that we hold about you. This enables you to have any incomplete or inaccurate information 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 information. This enables you to ask us to delete or remove personal information 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 information where you have 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 of 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 information where we are relying on a legitimate interest (or those 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 information 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 the restriction of processing

of your personal information. This enables you to ask us to suspend the processing of personal information about you, in the following scenarios:

1. If you want us to establish the data’s accuracy.
2. Where our use of the data is unlawful but you do not want us to erase it.
3. 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.
4. 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 information to another 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 aect 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.

• Make a complaint

to a supervisory body which in the United Kingdom is the Information Commissioner’s Oce. The ICO can be contacted through this link: https://ico.org.uk/concerns/

Last updated: 26/03/2024