Compass Underwriting Ltd strongly believes in protecting your privacy and the confidentiality of your Personal Information. In order to explain how Compass collects, uses and protects Personal Information, we have developed this Privacy Notice. Personal Information is any combination of information, in the possession of or likely to come into the possession of Compass, that can be used to identify, contact, or locate an individual (“Personal Information”) and will be treated in accordance with this Privacy Notice. This includes any expression of opinion about such individual. Any information which cannot be used to identify an individual (such as aggregated statistical information) is not Personal Information.
This Privacy Notice covers the information practices of websites that link to this Privacy Notice (each referred to as a “Site”). The data controller of this website is Compass Underwriting Ltd, whose registered number is 3332314 and whose registered office is at Brierly Place, New London Road, Chelmsford, Essex CM2 0AP
Compass may collect, use and disclose your Personal Information (including individuals associated with you, all of whom are referred to as “you” in this Privacy Notice) in its normal course of business for the following purposes:
The information gathered by Compass from this Site falls into two categories: (1) information voluntarily supplied by visitors to our Site and (2) tracking information gathered as visitors navigate through our Site.
Information Voluntarily Provided By You
When using this Site, you may choose to provide us with information to help us serve your needs. The Personal Information that we collect will depend on how you choose to use this Site.
If you request a brochure or report or further information from us, we require you to submit your name, e-mail address, the name of your organization, and the country in which you are based so we may send you the material you have requested, and to enable us to identify if you are an existing client of Compass.
If you register with the Site or request an insurance quote, we may ask you for your name, e-mail address, country, telephone number and the reason for your communication, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you with the quote. On the data submission form, we shall indicate by way of an asterisk, which information is optional and which information is mandatory. This information can include:
Any Personal Information that you provide will be used for the purpose indicated on the Site or in this Privacy Notice.
Following the quote, if you decide to proceed, we will collect Personal Information necessary to finalise the relevant quote and proceed with the transaction, such as your name, address, postcode, contact telephone number, e-mail address, billing address or payment details, as relevant to the product. We will use your Personal Information to administer your policy, process claims and generally manage your relationship with us. We may pass the Personal Information you provide to others. Please see the Disclosure of Information to Others section for information on the categories of recipients of Personal Information.
Finally, if you submit content regarding any of the information that you view on our Site, we will ask for your name and e-mail address, so that, if you choose, we can update you by e-mail when others also comment on the content, and also so that we can manage the content in line with our Terms & Conditions. You should be aware that the information you provide there will be made publicly available to Compass employees and other users of the Site.
Website Navigational Information – Cookies
Cookies are small text files that are placed on your computer by websites that you visit. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
We do not disclose any Personal Information about you to any third parties except as stated in this Privacy Notice, as otherwise permitted by law, or authorised by you.
Third parties to whom we disclose your Personal Information are required by law and contractual undertakings to keep your Personal Information confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation. The purposes for which we may disclose your Personal Information to third parties are as follows:
If these third parties wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent.
In the normal course of performing services for our clients, Personal Information may be shared within Compass and its affiliates for research and statistical purposes, system administration and crime prevention or detection. This may require Personal Information to be accessed or moved to a country different from the one where the Personal Information was collected. When you supply us with information containing third party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform general insurance and other services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason(s) for obtaining the Personal Information, the fact that it may be disclosed to third parties such as Compass, and have consented to such disclosure and use.
As a number of the service providers (including certain Compass affiliates) we use are located in countries outside the European Economic Area (“EEA”), including the United States, your Personal Information may be transferred to countries, which do not have as robust a data protection regime as those countries within the EEA.
The transfer of Personal Information is governed by European Union (EU) standard contractual clauses, the EU-US Privacy Shield or equivalent data transfer agreements to protect the security and confidentiality of your Personal Information.
As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either Compass itself or substantially all of Compass assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third party purchaser in these circumstances.
Other Legally Required Disclosures
Compass preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site if Compass has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of Compass, employees, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request.
In this Privacy Notice, the purposes identified above and in “Collection, Use and Disclosure of Personal Information” will be referred to as the “Identified Purposes.”
Your knowledge of and consent to Compass’s collection, use and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:
Where Compass relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorised representative such as a legal guardian, agent or holder of a power of attorney.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. Compass will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for Compass to collect, use or disclose your Personal Information could mean that we cannot obtain insurance coverage or other requested products, services or information for you.
If you wish to withdraw your consent please refer to the Questions or To Withdraw Consent sections below.
However, there are a number of instances where Compass does not require your consent to engage in the processing or disclosure of Personal Information. Compass may not solicit your consent for the processing or transfer of Personal information for those purposes which have a statutory basis, such as:
Compass will collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose, and subject to your consent (where appropriate), that new purpose will become an Identified Purpose.
Compass will collect Personal Information by fair and lawful means. We will normally retain Personal Information as long as necessary for the fulfilment of the Identified Purposes. However, some Personal Information may be retained for longer periods as required by law, contract, or auditing requirements.
We have in place physical, electronic and procedural safeguards appropriate to the sensitivity of the information we maintain regarding Clients and Participants. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Among such safeguards are the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties, and similar security protocols. However, due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information, and Compass expressly disclaims any such obligation.
Compass Sites may include links to other websites whose privacy policies we do not control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your web browser), use of any Personal Information you provide is governed by the privacy notice of the operator of the website you are visiting. That notice may differ from ours. If you can’t find the privacy notice of any of these websites via a link from the website’s homepage, you should contact the website directly for more information.
It is important that the Personal Information (e.g. email address) that we hold about you is accurate, complete and up-to-date. If any of your details change you can update us by e-mailing us at firstname.lastname@example.org. Please keep us informed of changes to your Personal Information.
You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete or incorrect. However, to secure your Personal Information, Compass does not provide online access to its customers to view or amend Personal Information in its database.
You may exercise your right to withdraw your consent to applicable uses or disclosures of your Personal Information (which may limit or terminate the products and services that Compass provides to you) by writing to us at the above address. We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information.
Normally we will respond to access requests within 30 days.
If you have any questions about this Privacy Notice, want to access your Personal Information or wish to make a complaint about this Privacy Notice, you can do so by writing to our Customer Services Manager at the following address – Customer Services Manager, 50 Mark Lane, London. EC3R 7QR or email@example.com
The Privacy Notice is subject to change at any time. It was last changed on February 2018.