IMPORTANT INFORMATION AND WHO WE ARE
Our website is not intended for children and we do not knowingly collect data relating to children.
Data Protection Officer
Full name of legal entity: Intelligent STORM Solutions Ltd
Email address: DPO@istormsolutions.co.uk
Postal address: 7 Whitehill Buildings, Alderminster, CV37 8BW
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.
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, policy number, national insurance number, claim 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.
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 offences.
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:
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
Other third parties or publicly available sources
We will receive personal data about you from various third parties and public sources as set out below:
- Identity, Contact, and Claims Data from data brokers or aggregators.
- Identity, Contact, and Claims Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
Automated technologies or interactions
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact(c) Technical||(a) Necessary for our legitimate interests or those of a third party (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical||Necessary for our legitimate interests or those of a third party (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests or those of a third party (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and Communications||Necessary for our legitimate interests or those of a third party (to develop our products/services and grow our business)|
|To disclose data relating to fraudsters or scammers as part of a criminal or civil investigation to the relevant authorities as required by law||(a) Identity(b) Contact(c) Profile(d) Usage(e) Technical(f) Transaction(g) Claims||Necessary for our legitimate interests or those of a third party (to prevent or detect fraud)Necessary to comply with a legal obligation.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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, including:
- Web Hosting services.
- Google Analytics
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;
- 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 firstname.lastname@example.org 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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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 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.
- Make a complaint
to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Last updated: 09/11/2022