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1. Privacy Policy

Definitions: 

We, Us, Our, KEYGENI LTD – refers to KeyGeni Ltd and its subsidiary companies.

Data Protection Legislation – refers to all applicable privacy and data protection laws including (i), the Data Protection Act 2018 (ii) the General Data Protection Regulation ((EU) 2016/679) (iii) the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426) and any further or additional national implementing laws, regulations, secondary legislation and binding guidance and codes of practice issued by the Information Commissioner or any other data protection authority in England and Wales relating to the processing of Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time.

Introduction

Welcome to our privacy policy. 

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data 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 we collect and processes your personal data through your use of this website or the KEYGENI LTD Mobile App.

The website nor the KEYGENI LTD Mobile App are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy in conjunction with other notices and policies. If you are directed to a third party website, the terms of their privacy policy will apply. 

Controller

KeyGeni Ltd is the controller and has responsibility for protecting  your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below. 

Changes to this Privacy Notice and your duty to inform us of changes

We keep this privacy policy under regular review. This version was last updated in May 2021. 

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.
Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal Data we receive

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 (including your first name, last name, marital status, title, gender and multi media images);
• Contact data  (including your address, delivery address, email address, telephone contact numbers, website address and social media contact information);
• Financial Data (including bank account and payment card details).
• Usage Data (including information about how you use our website, products and services]. 
• Marketing and Communications data (including your preferences in receiving marketing from us and your communications preferences);

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 do not generally 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). 

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 your Identity, Contact and Financial Data by      filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
  • Report a claim to your insurer;
  • express an interest in services;
  • Subscribe to emails communication;
  • request information about KEYGENI LTD services;
  • attend an KEYGENI LTD event, including virtual events promoted, supported or facilitated by KEYGENI LTD;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us. 

How your personal data will be used?

1.    We will only use your data in circumstances where the data protection legislation allows us to. Most commonly, we will use your personal data in the following circumstances:

• a.    Where we need to perform services under a contract with your insurer;
• b.    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;
• c.    Where we need to comply with a legal obligation;
• d.    Where we have received your informed and specific consent to do so.

2. KEYGENI LTD and its subsidiaries operate in an integrated way. When consenting to the sharing of your personal data for requested services, you are consenting to KEYGENI LTD sharing your data and for the subsidiaries to process your data.

3. We will only use your 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.  We can explain this to you.  If we need to use your data for an unrelated purpose, we will notify you and explain why we can do this.  Please note that we can process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing 

Your personal data may be used to:- 

1. Provide you with a more personalised experience whilst using our website, including advertisements for relevant services and products.
2. Keep you informed about services and products available to you as an KEYGENI LTD customer unless you have told us that you do not wish to receive such information. This could be by email, postal mail, phone or text.

Opting out    

You can ask us to stop sending you marketing messages at any time by contacting us using the below details.

Sharing Personal Information 

We may disclose your personal information to third parties in the following circumstances:

• When a specific service is being provided on      our behalf. We will ensure that your personal information is handled as if      we were processing it ourselves and under the same terms as this privacy      notice. We will only share the minimum information that they need to undertake the service and we will ensure that they keep your information secure.
• When we are providing a service on your behalf. 
• When you have requested information about a service or product provided by an affiliated partner and only with your specific consent.
   

Data security

We have put in place appropriate security measures to prevent your personal data from 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.

Data retention

How long will we use your personal data for?

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. 

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

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

Under the data protection legislation you have a number of rights with regard to your personal 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 data that we hold about you. This enables you to have any incomplete or inaccurate data 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 data. This enables you to ask us to delete or remove personal data 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 data where you have successfully 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 data 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 data 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 restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data 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 data to you or to a third 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.

You do not have to pay any fee to request access to the personal information that we hold.  However, if your requests become unfounded, repetitive or excessive we have the right to refuse your request or charge you a reasonable fee.
 

Complaints

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.

Identity and contact details of controller and data compliance advisor

KeyGeni Ltd is the controller of data for the purposes of the data protection legislation.

If you have any concerns as to how your data is processed, or if you have any questions about this privacy policy or our privacy practices more generally, you can contact our data compliance managers at info@keygeni.com or you can write to us at:

FAO Data Compliance Manager
KeyGeni Ltd, Investment House, Bolton Road, Bradshaw, Bolton, BL2 3EU.