INTRODUCTION

ADVA Group Limited registered number: 12899962, registered address Elizabeth House, 8th Floor, 54-58 High Street, Edgware, Middlesex, HA8 7TT, United Kingdom and references to ADVA refer to the applicable entities of ADVA Group Limited including (but not limited to) affiliates and subsidiaries of ADVA Speciality Limited, registered number: 12490563, registered address Elizabeth House, 8th Floor, 54-58 High Street, Edgware, Middlesex, HA8 7TT, United Kingdom.

ADVA respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data which you provide to us, or which we obtain when providing services to you from any one of our Group companies when you use one of our websites or when we deal with you in the course of our business.

This policy applies to personal data we hold relating to policyholders, brokers, professional contacts and other third parties. Depending on who you are and how you interact with us, only some aspects of this policy may apply to you.

Changes to this policy

We may update this privacy policy from time to time – you can find our latest policy on our website or ask us for a copy.

We primarily handle only commercial insurance and do not deal in personal lines business. To that end, little of the data we hold is classed as Personal Data.

The Regulation defines Personal Data as any information relating to an identified or identifiable natural person (a Data Subject); an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

As a specialist managing general agent dealing with brokers and commercial clients, we understand the importance of maintaining your privacy, keeping your personal information secure and complying with data protection laws.

We are the data controller of any personal information you provide to us. This means that we are responsible for complying with data protection laws. This privacy policy describes what personal information we may collect from you, why we use your personal information and, more generally, the practices we maintain and ways in which we use your personal information.

By providing your personal information to us, you acknowledge that we may use it in the ways set out in this privacy policy. We may provide you with further notices highlighting certain uses we wish to make of your personal information. We may also give you the ability to opt-in or opt-out of selected uses such as marketing when we collect your personal information.

From time to time, we may need to make changes to this privacy policy, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally. You should check our website periodically to view the most up to date privacy policy.

Our Privacy Policy is divided into the following sections to help you find the area you are interested in.

SECTION 1: WHO DO WE COLLECT PERSONAL INFORMATION ABOUT?

  • present, past and prospective brokers and insurers;

  • present, past and prospective employees of brokers and insurers;

  • clients and prospective client’s directors and/or employees;

  • third party and client employee claimants;

  • employees of insurers and loss adjusters;

  • office suppliers;

  • designated contacts at certain UK trade associations with whom we have dealings; or
  • users of our website.

SECTION 2: WHEN DO WE COLLECT PERSONAL INFORMATION?

We might collect your personal information if you:

  • or your employee asks to be part of a mailing or marketing campaign;
  • submit details with prospective and current client enquiries;
  • submit claim details;

  • apply (or someone on your behalf) applies for your employees to have access to our extranet;
  • submit our online survey;
  • use our website “find a local broker service or plan ahead”;
  • use our website live helper service;
  • telephone us with a technical or cover query; or
  • use our website (for more information, please see section 14 on Cookies and section 15 on Pixel Tags).

SECTION 3: WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We may collect the following (non-sensitive) personal information:

  • name;

  • email address;

  • business and/or mobile phone number;
  • business address; 

  • job title and company name;
  • IP address;

  • types of insurances you are interested in; or
  • financial details if available from public records.

We may also collect the following sensitive personal information submitted with claims on medical history and other personal details.

SECTION 4: HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We may collect your (non-sensitive) personal information:

  • face-to-face (directly from you);
  • by telephone;

  • via call recordings;

  • by email;

  • via our website (including through the use of cookies – please see section 14 on Cookies);
  • via enquiries submitted by agents;

  • via our find a local broker and plan ahead service;

  • via our website live helper service;
  • via claim details submitted;

  • via the key contact at your organisation (where you work for a broker) who is responsible for registering all applicable employees;
  • from member lists obtained from trade associations;
  • from publicly available sources including but not limited to internet search engines, public records and registers (including companies house) and social media (e.g., LinkedIn and Twitter); or
  • through cookies placed on our website (see section 14 on Cookies).

SECTION 5: PURPOSES FOR WHICH WE PROCESS YOUR (NON-SENSITIVE) PERSONAL INFORMATION

We use your personal information for many different purposes.

Under data protection laws, for each purpose, we must be able to rely on a legal ground to justify why we are using your (non-sensitive) personal information. The legal grounds that we may rely on are:

FOR PROCESSING (NON-SENSITIVE) PERSONAL INFORMATION LEGAL GROUND DETAILS

Performance of our contract with you

Processing is necessary for the performance of a contract to which you are party to or in order to take steps at your request prior to entering into a contract.

Compliance with a legal obligation

Processing is necessary for compliance with a legal obligation to which we are subject.

For our legitimate interests where these do not cause you undue harm

Processing is necessary for the purposes of the legitimate interests pursued by a third party or by us, except where such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal information.

Our main legitimate interests for using your personal information are:

(1) to enable us to provide insurance quotations and handle claims; and
(2) to promote ADVA services and the value of the services that we offer and to keep you updated on product developments and news.

When we use your sensitive personal information (for example, information about your medical history, criminal convictions, or health), we must be able to rely on an additional legal ground. The additional legal grounds that we may rely on in these instances are:

FOR PROCESSING SENSITIVE PERSONAL INFORMATION

Your explicit consent

You have given your explicit consent to the processing of your sensitive personal information for one or more specified purposes.
You may withdraw your consent at any time by contacting us. If you do so, you may not be able to receive the benefit of some of our services, where in order to provide them, we rely on your explicit consent to process your sensitive personal information.

For legal claims
Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

You have made this information public

You have made your sensitive personal information manifestly public.
For every use of your personal information, we have set out the relevant legal grounds that we will rely on and, where relevant, the additional legal grounds that we rely on when we use your sensitive personal information.

Where you deal with us, the personal information that we collect about you may be used:

1. To administer your dealings with us

Legal grounds?

  • As part of trading with you, we need to carry out our obligations arising from the contract and general service activities such as quotations, claims handling invoicing and confirmation emails
  • Performance of our contract with you
Additional legal grounds for sensitive personal information?
  • for legal claims

2. To send you any guides, documentation, email alerts or other information relevant to you or your company

Legal grounds?

  • Performance of our contract with you
  • Legitimate interests

3. To track email readership

Legal grounds?

  • Performance of our contract with you
  • Legitimate interests

4. To personalise your experience on our website

Legal grounds?

  • Performance of our contract with you
  • Legitimate interests

5. To track the use of our website

Legal grounds?

  • Performance of our contract with you
  • Legitimate interests

6. To review prospective employees and maintain current staff records

To enable us to consider potential new employees and maintain existing staff records we ask for relevant employment information, including CV’s, medical and sickness details, bank details and the like.

Legal grounds?

  • Performance of our contract with you
  • Legitimate obligations

Additional legal grounds for sensitive personal information?

  • for legal claims
  • explicit consent

7. For marketing purposes

We may send you marketing emails about our products and services. For more information about marketing communications, please see section 7 on marketing.

Legal grounds?

  • Performance of our contract with you
  • Legitimate interests

Where you make enquiries of us as a sole trader or on behalf of a firm, the personal information that we collect about you may be used:

To provide information about us and our products

Legal grounds?

  • Performance of our contract with you
  • Legitimate interests

SECTION 6: WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We may disclose your personal information to the third parties listed below for the purposes described in this privacy policy. You can contact us for details of specific disclosures made in respect of your personal information. The third parties listed below will only use your personal information under our strict instruction and are under an obligation to ensure appropriate security measures are in place.

  • Insurers;
  • Loss adjusters;

  • Professional advisors including auditors, solicitors, tax advisors and media sales agencies;

  • IT and mailing service providers; or

  • Regulators (including the Financial Conduct Authority);

We may also disclose your personal information to other third parties where:

  • the disclosure is required by law or by a regulator with authority over us or you, such as where there is a court order, statutory obligation or FCA request; and
  • we believe that such disclosure is necessary in order to assist in the prevention or detection of any criminal action (including fraud) or is otherwise in the overriding public interest.

SECTION 7: MARKETING

We are committed to only sending you appropriate and relevant information on our products and services. More details on the marketing communications that we send can be found below.

You can opt out of further emails by following the link appearing at the bottom of any marketing email.

Where you are a sole trader or an employee of a sole trader firm:

We are committed to sending you appropriate and relevant information on our products and services, including:

  • Information on new products and services;
  • Guides on our products and services;
  • Cover updates;

  • New on our company;

  • General updates; and

  • Training updates;

If you wish to unsubscribe from the communications sent by us to you, you may do so at any time by clicking on the “unsubscribe” link that appears at the bottom of all marketing email communications. Otherwise, you can always contact us.

However, please note that individuals who are key contacts at their organisation will receive essential emails, which will include, at a minimum, regulatory and cover issues.

SECTION 8: HOW WE PROTECT YOUR PERSONAL INFORMATION

ADVA is committed to keeping your personal information secure. We keep your personal information in a secure server and have appropriate security measures in place in our physical facilities.

Whilst we strive to protect your personal information, due to the nature of the internet, we cannot guarantee the security of any information you transmit to us. Any transmission is at your own risk, and we urge you to take every precaution to protect your personal information while you are online.

SECTION 9: HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We only keep your personal information for as long as is reasonably necessary to fulfil the relevant purposes described in this privacy policy, or if required by law we may keep your information for longer.

SECTION 10: INTERNATIONAL DATA TRANSFERS

We (or third parties acting on our behalf) may store or process personal information that we collect about you in countries outside the European Economic Area (“EEA”), which may have lower standards of data protection.

We may also disclose your personal information to third parties in connection with the sale, transfer or disposal of our business, provided that they continue to use your personal information substantially in accordance with the terms of this privacy policy.

In the unlikely event that we transfer your personal information outside the EEA, we will ensure that an adequate level of protection is in place to protect your personal information, such as putting in place contractual protections which have the purpose of ensuring the security of any information passed and putting in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information.

SECTION 11: YOUR RIGHTS

1. The right to access your personal information
Subject to any relevant exemptions, you are entitled to see a copy of the personal information we hold about you and to request details of how we use your personal information, including any disclosures made. To exercise your rights to access your personal information, please contact us. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case your personal information will be provided to you by electronic means where possible.

2. The right to rectification
We take reasonable steps to ensure that the personal information we hold about you is reliable and as accurate and complete as is necessary for its intended use but you are entitled to ask us to update or amend any inaccuracies in the personal information that we hold about you. To request us to update or amend any personal information we hold about you, please contact us.

3. The right to object to marketing
As set out in section 7 on marketing, you are entitled to object to receiving marketing material from us at any time. You can exercise this right by clicking ‘unsubscribe’ on any marketing email you receive from us or by contacting us.

4. Other rights
Under certain conditions, you may also have the right to require us to:

  • delete any personal information that we no longer have a legal ground to rely on;
  • where processing is based on consent, to withdraw your consent so that we stop that particular processing;
  • object to any processing based on the legal ground of legitimate interests unless our reason for undertaking that processing outweighs any prejudice to your data protection rights;
  • provide you or another provider with a copy of your personal information that you provided us with; and
  • restrict how we use your personal information whilst a complaint is being investigated.

If you contact us to exercise any of these rights, we will confirm your right to do so and respond in most cases within 30 days.

SECTION 12: YOUR RIGHT TO COMPLAIN TO THE INFORMATION COMMISSIONER’S OFFICE

If you are not satisfied with our use of your personal information, our response to any exercise of your rights set out in section 11 on your rights, or if you believe us to be in breach of our data protection obligations, you have the right to complain to the Information Commissioner’s Office.

SECTION 13: OTHER WEBSITES

Our websites may contain links to other third party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.

SECTION 14: COOKIES

Cookies are small text files placed on your computer and are commonly used on the internet. There are various types of cookies that perform different functions, such as remembering which items you have placed in your shopping basket or analysing your browsing behaviour to enable advertisers to present you with adverts more relevant to you and your interests. For more information about cookies, visit www.allaboutcookies.org.

ACCEPTING OR REJECTING COOKIES

Most web browsers will accept cookies, but if you would prefer we did not collect data by this method, you can disable this function within your browser settings. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies.

We may use cookies to:

  • Collect information that will help us to distinguish visitors, to understand visitors’ browsing habits on our website and to improve their experience.
  • Compile statistical reports on website activity, e.g. numbers of visitors and the pages they visit.

  • Collect information that will allow us to tailor advertising to make it more relevant for you, based on your previous interactions with our website.

  • Remember information about you when you visit our site. Some of the cookies are essential in order to provide our services to you.

Below, we have set out the four categories of cookies that we may use on our website. These cookies are:

  • Strictly necessary cookies
  • Performance cookies
  • Functionality cookies
  • Targeting cookies

This website may also include third-party cookies, which are cookies not set by us. In each of the four categories above, we have specified where third party cookies are used.

The following types of cookies may be used during your visit to our website:

STRICTLY NECESSARY COOKIES
These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the website, all of which enables us to see how visitors use the website in order to improve the way that our website works. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our website works.

*To opt out of being tracked by Google Analytics across all websites please visit https://tools.google.com/dlpage/gaoptout. These cookies will be reviewed and updated on a quarterly basis.

PERFORMANCE COOKIES
These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the website, all of which enables us to see how visitors use the website to improve the way that our website works. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our website works.

FUNCTIONALITY COOKIES
These cookies allow a website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a website may be able to provide you with news or updates relevant to the policies you buy. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.
These cookies will be reviewed and updated on a quarterly basis.

TARGETING COOKIES
These cookies are not used on this website. These cookies collect several pieces of information about your browsing habits. They are usually placed by advertising networks rather than website operators. They remember that you have visited a website and share this information with other organisations such as advertisers. They do this in order to provide you with targeted adverts more relevant to you and your interests. Quite often they will be linked to site functionality provided by the other organisation. Although the cookies can track your visits around the web they do not usually know who you are. Without these cookies, online advertisements you encounter will be less relevant to you and your interests.

These cookies will be reviewed and updated on a quarterly basis.

These cookies will usually be third-party cookies, although if you are visiting the advertising network’s own website, it is technically possible these could be first-party cookies. These cookies can be associated with services provided by a third party, but this is not always the case. All information these cookies collect is anonymised, although they contain a unique key that can distinguish individual user browsing habits or store a code that can be translated into a set of browsing habits or preferences. Generally speaking, the third party’s Privacy Policy on their website will indicate if the cookie is being used as part of an advertising network.

Examples include:
Cookies placed by advertising networks to collect browsing habits in order to target relevant adverts to you. The site you are visiting need not actually be serving adverts, but often this will also be the case.

Information on deleting or controlling cookies is available at www.allaboutcookies.org.

Please note that if you disable cookies, the website functionality may be impaired and prevent you from obtaining a quotation or completing your purchase online.

SECTION 15. PIXEL TAGS

Pixel tags (also called clear gifs or web bugs) are used to track who is reading a web page or email, when, and from what computer.

They provide us with information about your interaction with our email messages (if you receive messages in html format) and to record some of the pages you consequently visit on our Website.

We use this information so we can provide you with information tailored to your needs and interests, better plan our future campaigns and upgrading visitor information used in reporting statistics.

Pixel tag technology is used to analyse the reading habits of our membership in order to review and improve services to members and on occasion, may use this for marketing purposes. Questions about this technology should be directed to us.

SECTION 16. HOW TO CONTACT US

Please contact us if you have any questions about our privacy policy or the information we hold about you.

You can contact us by email at dermot.reilly@advauw.com

SECTION 17. HOW TO MAKE A COMPLAINT

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you believe we have not handled your information as set out in this Privacy Notice, or that we have processed your personal information in a manner that is not consistent with your rights, please contact us, and we will do our utmost to make things right.

If you are still unhappy, you can complain to the Information Commissioner’s Office. Their contact details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow Cheshire SK9 5AF
United Kingdom
Tel: 0303 123 1113 (local rate) or 01625 545 745
Website: www.ico.org.uk

CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice is subject to change at any time. It was last changed on 27th July 2021. If we make changes to this Privacy Notice, we will update the date it was last revised.