Privacy Policy

At we respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.


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.

Please read the following carefully together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you to understand our views and practices regarding your personal data and how we will treat it so that you are fully aware of how and why we are using your personal data. 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 LTD registered with the Information Commissioners Office (“ICO”) in the UK under registration number ZA504194 is the controller and responsible for your personal data (collectively referred to as “”, “we”, “us” or “our” in this privacy policy).

Data Protection Officer

Our Data Protection Officer is Michael Blakeley who is 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

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: LTD

Email address:

Postal address: Unit 3, Building 2, The Colony Wilmslow, Altrincham Road, Wilmslow, England, SK9 4LY

Telephone number: +44 7852 115490

You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.


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:

  • 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. 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 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.


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 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.

Sourced from our Customer or other publicly available sources

Our System relates to our AI fraud detection and automation services and typically will include information provided by our customers regarding their customers/ claimants. When you make a claim against a policy underwritten by our Customer, or you are involved in an incident for which a third party has made a claim against such a policy and our Customer has engaged us to assist we will collect and process Identity, Contact, Financial, Transaction, Technical and Claims Data We will receive this information from our Customers, their representatives, medical professionals, the police, and other publicly available sources.

This personal data may include criminal conviction data and special categories of sensitive personal data.

To the extent that it is necessary for us to process Special Category Personal Data, we will process it in accordance with the applicable data protection laws. Typically, this will be where the processing is necessary for performing our contract with our Customer and for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity. On occasion we may need to obtain your explicit consent, or (in the case of another data subject’s special category personal data) require you to obtain thedata subject’s explicit consent, before we can process that special category personal data.

We may only process information relating to criminal convictions or criminal records etc in accordance with the applicable data protection laws. Typically, this will be where the processing is necessary for performing our contract with our Customer and necessary for the purpose of, or in connection with, any claims or potential legal proceedings, or is otherwise necessary for the purposes of establishing, exercising or defending legal rights, or for the prevention or detection of fraud, or where you have already made the information public. On occasion, we may need to obtain your explicit consent, or (in the case of another data subject) require you to obtain the data subject’s explicit consent before we can process information relating to criminal convictions

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

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

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.


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:
  • Performance of a contract: To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us in terms of anti-fraud and protection from fraudsters and scammers.
The core service we offer to our customers is the automated review of insurance claims and the detection of fraudsters, consisting of the following:
  1. AI will help us to accurately detect fraudsters, can differentiate between fraudsters and genuine users, and can identify fraudster trends which are emerging in your systems;
  2. Automated decision making will improve the speed and efficiency of your claims and improve genuine claims and reduce the cost of fraudulent claims, the net result being improved accuracy and speed of payouts. only proceeds with automated decision making in the case that the insurer has obtained customer consent about processing their personal data
  • 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 register you as a new customer Persistent Performance of a contract with you
To provide our anti-fraud prevention and detection solution:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing & Communications
(g) Claims
(h) Technical
(a) Performance of a contract with you
(b) Necessary for our legitimate interests or those of a third party (to prevent and detect fraud)
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy (a) Identity
(b) Contact
(c) Financial
(d) Marketing & Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests or those of a third party (to keep our records updated and to study how customers use our products/services)
To enable you to provide feedback to us (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing & Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests or those of a third party (to study how customers use our products/services, to develop them and grow our business)
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 & 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 & 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
(a) Necessary for our legitimate interests or those of a third party (to prevent or detect fraud)
(b) Necessary to comply with a legal obligation.
To grade the quality of our data sources from insurers and third parties in order to verify the quality. We do not automate decisions on individuals. we don’t make automated decisions about inidivuals, we only automate quality testing about the data that we source. Data is sourced from the insurer, public sources and private companies (who have acquired the data legally and with consent of the user). (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Technical
(f) Claims
(a) Necessary for our legitimate interests or those of a third party (to prevent or detect fraud)
(b) Necessary for our legitimate interests or those of a third party (to test the quality of our data sources and systems)
(c) Consent
(d) Necessary to comply with a legal obligation.


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


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. For detailed information on the cookies we use and the purposes for which we use them see our Cookie notice:

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.


International Transfers

Information may be accessed by users of the Systems or shared information who have travelled or reside outside of the EEA.

As a global service we may also transfer data outside of the EEA to service providers located outside the EEA, in such circumstances we will seek to ensure that appropriate safeguards are put in place and perform the necessary due diligence.

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use 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.
Please contact our DPO, Michael Blakeley at if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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:

  • Other users of the System for the purpose of identifying fraudsters;
  • clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
  • 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;
  • professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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:
  • Amazon Web Services, our hosting partner. We use Amazon, a top tier data hosting service, to host our service and keep our data safe.
  • Namecheap Website Hosting services.
  • Xero accountancy software to manage accounts and payment systems.
  • GSuite to manage our documents and emails and to keep our data secure.
  • Rebump, a CRM software to help us engage with our customers.
  • LinkedIn to contact with other companies to develop business opportunities.
  • Trello as a secure messaging platform to keep in share progress on different internal projects.
  • Slack communication system.
  • Business partners, suppliers and sub-contractors for the provision of the service to you.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our website.
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 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, 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 by Amazon servers within the EEA however it may be transferred to, and accessed, in destinations outside the European Economic Area (”EEA”).

It may be transferred to third parties outside of the EEA for the purpose of fulfilling our anti-fraud detection and prevention services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our anti-fraud services and the provision of support services. By submitting your personal data and that of your users you agree to this transfer, storing or processing. LTD will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology or through bank transfer. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our system, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 your 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 to try to prevent unauthorised access.

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.

At the end of our contract with you we will delete data in line with our contractual provisions/ as agreed and our Data Retention Schedule, however please note that any machine learning processes and techniques will stay with us as part of our IP.

  • YOUR LEGAL RIGHTS (please contact 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.
  • 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 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:

Password Restrictions

At Limited all users are required to set a strong password (at least 8 characters with special characters and password blacklisting) which will have to be changed if there are pressing reasons, such as a personal data breach. We would ask that if you are a user of our system that you keep your password safe and report any loss/breach of your passwords to us as soon as practically possible.

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.


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