Privacy and cookies policy

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Last updated: 29 April 2021

The purpose of this Privacy Policy is to inform you how Bewica Limited obtains,processes and protects personal data obtained through its website www.bewica.com (the "Website"), in its capacity as Data Controller and in accordance with the provisions of the General Data Protection Regulation ("GDPR").

Personal data or personal information means any information about an individual which makes it possible to identify that individual.

For other terms used in this Policy, please refer to the definitions in the GDPR, in particular Article 4.

1. Data controller

Bewica Limited is the Data Controller for the processing of personal data obtained through the Website. Its contact details are as follows:

-       Postal address: 27 Old Gloucester Street,London, WC1N 3AX, UK.

-       E-mail address: [email protected]

-       Telephone number: +44 (0)20 3026 5840

2. Representation for data subjects in the EU

We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/12916457917

3. The personal data that are processed

Bewica Limited collects, processes, stores and transfers personal datathat Users of the Website ("Users") provide through the Website and/or that is obtained by Bewica Limited through cookies installed on the Website. This personal data may fall into the following categories:

-       Contact data: including name, surname, e-mailaddress, telephone number and address of the Users.

-       Technical data: including IP address, login details, browser type and version, time zone setting and location, operating system and other technologies of the devices Users use to access the Website.

-       Profile Data: including the User name and password, and the comments and responses that Users provide in surveys on theWebsite.

-       Usage data: including information on how Users use the Website and the products and services offered through it.

-       Marketing Data: including Users' preferences regarding the receipt of advertising and commercial communications about Bewica Limited and third party products and services.

-       Cyber Security Data: including data relating tothe cyber security of the company to which Users belong, which may be sharedwith Bewica Limited or obtained by Bewica Limited from third parties.

-       Financial data: including data that Users provide on the Website about their bank account and payment card.

-       Transactional Data: including data relating topayments made and products and services purchased by Users through the Website. If applicable, it also includes questions that Users ask us by email or via the Website chat.

4. Purposes and legitimate basis for processing

The personal data of Website Users may be processed by Bewica Limited for the purposes set out below. Depending on the personal data processing carried out and its purpose, the legitimate basis for the processing will bevone or the other. This is explained in detail in the table below.


Purpose of processing Legitimising basis
Responding to contact requests made by Users through the Website Application of pre-contractual measures (Art. 6.1.b RGPD)
Sending security and commercial communications related to products and services previously purchased by Users. Contractual relationship (Art. 6.1.b GDPR)
Sending commercial communications related to products and services offered by Bewica Limited or third parties. Consent of Users (art. 6.1.a RGPD)
To carry out activities of analysis, development and improvement of the Website, as well as to guarantee its security measures. Legitimate interest (art. 6.1.f RGPD)
Carry out measurement activities on the Website for commercial and advertising purposes. Consent of Users (art. 6.1.a RGPD)
Manage the navigation of Users through the Website by means of cookies. Technical cookies: Bewica's legitimate interest (art. 6.1.f RGPD) in the operation and improvement of the website.
Analytical, advertising and behavioural cookies: User consent (art. 6.1.a RGPD).
Improve and develop the range of products and services offered on the website. Legitimate interest (art. 6.1.f RGPD)
Create customer accounts on the website, manage the customer portal and subscriptions. Contractual relationship (Art. 6.1.b GDPR)

5. Deletion and retention of data 

Users' personal data will be retained by Bewica Limited for as long as necessary to fulfil the purpose for which they were collected. Once this time has elapsed, Bewica Limited will proceed to their deletion, except when it must keep them for a longer period in order to comply with applicable legal obligations. 

In some circumstances you can request deletion of your personal data, please see the "Data protection rights" section below for more information. In particular, you can request deletion of your customer account by sending an email to [email protected] The account will be inaccessible for 14 days and then the data will be permanently deleted.

We may also in some circumstances anonymise your personal data (so that it can no longer be associated with you) and process it in anonymised form for research or statistical purposes, in which case we may use this information indefinitely without further notice.

6. Recipients of personal data

In order to provide certain services offered on the Website Bewica Limited needs to transfer your personal data to third party companies. These companies may process your personal data as: (i) Processors, for example where they are service providers working for us (such as accountancy firms, hosting service providers or telephone service providers); (ii) Joint controllers, for example where they are partners of ours that have introduced you to us; and/or (iii) Independent data controllers, such as third party payment service providers or government agencies. 

Such transfers of personal data will only be carried out where necessary to comply with a legal obligation applicable to Bewica Limited, where necessary to fulfil our contractual relationship, to meet our legitimate interest (e.g. where necessary to fulfil internal administrative purposes), or on the basis of your consent (e.g. use of a supplier). 

The Website may include links to third-party websites, plug-ins and applications. By clicking on those links or enabling those connections you may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for how they treat your personal data. When you leave our Website, we encourage you to read the privacy notice of each website you visit.

7. International transfers

Some of the third parties with whom we share your personal data are located outside the European Economic Area (EEA) and UK, so the processing of your personal data may involve an international transfer of data.

Whenever we transfer your personal data outside the EEA and UK, we ensure that the recipient grants it an equivalent level of protection to that which applies within the EEA and UK under applicable data protection laws. To this end, we apply the following safeguards: 

  • We intend to transfer your personal data only to countries that the European Commission and UK consider to offer an adequate level of protection for personal data. 
  • When we need to transfer your personal data to countries outside the list above, we always do so under one of the safeguards provided for in Article 46 of the GDPR. 

Please contact us if you would like more information about the specific mechanism we use to transfer your personal data outside the EEA and UK.

8. Security measures

Bewica Limited will implement all necessary technical and organisational measures to protect personal data obtained through the Website and in particular to prevent such data from being disclosed, accidentally lost, processed, altered or accessed in an unauthorised manner.

All personal data obtained through the Website will be treated with absolute confidentiality. To this end, Bewica Limited limits access to your personal data strictly to those employees, agents, suppliers and other third parties who have a need to know. They will only process your personal data on the instructions of Bewica Limited and will be subject to contractual confidentiality obligations. 

Bewica Limited has established internal procedures to deal with any suspected personal data breaches. In the event of a breach of your personal data, we will notify you and the relevant authority where we are legally obliged to do so.

9. Data protection rights 

Users may exercise their rights of access, rectification, erasure, objection, restriction of processing and portability by sending a request to Bewica Limited at 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom, or to the following e-mail address: [email protected] 

If you believe that Bewica Limited has not processed your personal data in accordance with the law, you have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk).

10. Cookies

Our Website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the User's computer system. If a User accesses a website, a cookie may be stored on the User's terminal equipment. This cookie contains a string of characters that allows the User to be uniquely identified when the User re-accesses the website. Bewica Limited uses cookies on its Website to make the Website more user-friendly. Some elements of our website require that the User accessing the site can be identified even after a page change. 

Bewica Limited uses the following types of cookies on its Website:

Technical or strictly necessary cookies: These cookies are necessary for the Website to function and cannot be disabled on our systems. They are usually only set in response to actions you take that amount to a request for services, for example, setting your privacy preferences, logging in or filling in forms. You can set your browser to block or warn you about these cookies, but then some parts of the Website may not work. These cookies do not store any personal data. 

Performance cookies: These cookies allow us to count visits and traffic sources so that we can measure and improve the performance of our Website. They help us to know which pages are most and least popular and to see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Website and will not be able to monitor its performance.

Functional cookies: These cookies enable the Website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function properly.

Advertising Cookies: These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other third party websites. They do not directly store personal information, but are based on the unique identification of your browser and internet device. If you do not allow these cookies, you will experience less personalised advertising.

Our cookie management tool gives you the option to enable/disable each of the above categories of cookies, except for strictly necessary cookies. You can change your settings here: https://bewica.com/en/privacy-policy#ot-sdk-btn

Cookie management services are also provided by the US site "http://www.aboutads.info/choices/" or the EU site "http://www.youronlinechoices.com/".

In addition, you can also prevent the storage of cookies by deactivating them in your browser settings. However, some features on our Website will then not work properly.

On our Website we use our own and third party cookies, which allow us to analyse the browsing behaviour of our Users. This includes:

Google Analytics

We use Google Analytics, whose provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google uses cookies, which contain information about the use of the online service offering by Users and which are usually transferred to a Google server in the USA and stored there. 

We only use Google Analytics with IP anonymisation enabled. This means that the User's IP address is anonymised by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and anonymised there.

Insofar as the data is processed in the USA, we would like to point out that we rely on Google's standard contractual clauses, which we consider sufficient given the limited scope of the data transfer. These can be found here: https://support.google.com/analytics/answer/9012600.

The information obtained through these cookies is processed on the basis of our legitimate interest in evaluating the use of our online service offer and recording activities within the scope of this offer. In addition, other services related to the use of this online offer and the use of the Internet are provided. This enables Google to create anonymous user profiles of the users on the basis of the data processed.

The IP address transmitted by the User's browser is not merged with other Google data. In the event that the User does not agree to such data processing, there is the option to deactivate the setting of any cookies through the browser settings and/or our cookie management tool available at: https://bewica.com/en/privacy-policy#ot-sdk-btn

In addition, the User can prevent the collection of data generated by your cookies and related to your use of the online offer and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

For more information on the use of your data by Google, as well as on the settings and objection options, see Google's data protection declaration (https://policies.google.com/privacy) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Google AdWords and conversion measurement

We use cookies from Google "AdWords" whose provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, through which personal data are processed. With regard to the personal data processed in the USA, we point out that we rely on Google's      standard contractual clauses, which we consider sufficient given the limited scope of the data transfer. These can be found here: https://support.google.com/adspolicy/answer/10042247?hl=en-GB.Google "AdWords" allows us to place ads on Google's advertising network (e.g., in search results, in videos, on web pages, etc.) to be shown to Users who have a suspected interest in the ads. This allows us to better target ads in relation to our online services, to show Users only ads that potentially match their interests. For example, when a User is shown advertisements for products they have been interested in on other websites, this is called "remarketing". For this purpose, when you visit our Website and other websites on which the Google advertising network is active, Google will execute the code directly by Google and embed so-called (re)marketing tags (invisible graphics or code, also known as "web beacons") on the website. With their help, an individual cookie, i.e. a small file, is stored on the User's device (instead of cookies, comparable technologies can also be used). This file records the websites the User has visited, the content that interests him/her and the offers he/she has clicked on, as well as technical information about the browser and operating system, the referring websites, the time of visit and other information about the use of the online offer.

We also receive an individual "conversion cookie". The information obtained with the help of the cookie is used by Google to compile conversion statistics for us. However, we only know the total number of anonymous Users who have clicked on our advertisement and who have been redirected to a page with a conversion tracking tag. We do not receive any information that personally identifies Users.

User information is processed anonymously within the Google advertising network. This means that Google does not store or process, for example, the User's name or email address, but processes the relevant cookie-related data within anonymous user profiles. In other words, from Google's point of view, ads are not managed and displayed for a specifically identified person, but for the owner of the cookie, irrespective of who the owner of the cookie is. This does not apply if the user has expressly allowed Google to process the data without anonymisation. The information collected about users is transmitted to Google and stored on Google's servers in the USA.

Further information on the use of data by Google, as well as on the settings and objection options, can be found in Google's privacy policy (https://policies.google.com/technologies/ads) and in Google's advertising display settings (https://adssettings.google.com/authenticated).

Google Firebase

We use Google "Firebase" from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For data processed in the United States, we rely on the Google/Firebase standard contractual clauses, which we consider sufficient given the limited scope of the data transfer. These can be found here: https://firebase.google.com/terms/firebase-mcc.

Google Firebase is a platform for developers of applications, so-called "apps" for mobile devices and websites. This platform offers a number of functions which are listed at https://firebase.google.com/products/.

These functions include the storage of Apps that include App Users' personal data, content created by them or information relating to their interaction with the Apps (so-called "cloud computing"). Google Firebase also provides interfaces that allow interaction between App Users and other services, e.g. authentication via services such as Facebook, Twitter or via a combination of email passwords.

The evaluation of User interactions can be done with the help of the analysis service "Firebase Analytics". Firebase Analytics is designed to record how Users interact with an application. This involves logging events, such as opening the application for the first time, uninstalling, updating, blocking or frequency of use of the application. Events can also be used to record other interests of the User, e.g. certain functions of applications or certain topics. In this way, User profiles can also be created, which can be used, for example, as a basis for the presentation of advertising messages tailored to Users.

Google Firebase and Users' personal data processed by Google Firebase may also be used in conjunction with other Google services, such as Google Analytics and Google's marketing services and Google Analytics (in this case, device-related information such as "Android Advertising ID" and "Advertising Identifier for iOS" is also processed to identify Users' mobile devices). Google's privacy policy is available at https://policies.google.com/privacy. For more information about Google's use of data for marketing purposes, please see the following summary page: https://policies.google.com/technologies/ads?hl=en. If Users do not wish to receive interest-based advertising through Google's marketing services, they can use the opt-out and opt-in options provided by Google, which can be found at https://adssettings.google.com/.

Google Recaptcha

We integrate the bot detection function, e.g. when entering data in online forms ("ReCaptcha"), from the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

One Trust

We use a tool from OneTrust Technology Limited, 82 St John Street, London, EC1M 4JN, UK, to give you the opportunity to choose your cookie preferences. Information about data protection at One Trust and opt-out options can be found here: https://www.onetrust.com/cookie-policy/

FullStory

This website uses FullStory, a web analytics tool of FullStory, Inc., 1745 Peachtree Rd NW Suite G, Atlanta, GA 30309, USA, to collect and store data for marketing and optimisation purposes. Visits are also logged. The data collected with FullStory will not be used to personally identify the visitor to this website and will not be merged with the personal data of the bearer of the pseudonym until an account is created with Bewica. If you do not want your data to be stored, you can deactivate this function on all websites that use FullStory worldwide for the browser you are currently using by clicking on the following link: https://www.fullstory.com/optout/. 

We have configured FullStory not to collect personal data. In case there are any errors (e.g. configuration errors) and personal data is eventually processed in the USA, we would like to point out that we have signed an agreement with FullStory to ensure that it processes personal data in accordance with the data protection regulations in force in the European Union.

Hotjar

This website uses Hotjar, a web analytics tool of HotjarLimited, Dragonara Business Centre, 5thFloor, DragonaraRoad, Paceville St Julian's STJ 3141, Malta, to collect and store data for marketing and optimisation purposes. Visits are also logged. The data collected with Hotjar will not be used to personally identify the visitor to this website and will not be merged with the personal data of the bearer of the pseudonym until an account is created with Bewica. If you do not want your data to be stored, you can deactivate this function on all websites that use Hotjar worldwide for the browser you are currently using by clicking on the following link: https://www.hotjar.com/legal/policies/do-not-track/.

We have configured Hotjar not to collect personal data. In case there are any errors (e.g. configuration errors) and personal data is eventually processed outside the EU, we would like to point out that we have signed an agreement with Hotjar to ensure that it processes personal data in accordance with the data protection regulations in force in the European Union.

tawk.to

We offer a chat function on our website. We use tawk.to from tawk.to, Inc, 187 East Warm Springs Rd, SB298 Las Vegas, Nevada, 89119, USA. The information provided in the chat is stored in the reporting tool of tawk.to, Inc on our behalf. Communication via chat takes place over an encrypte`d internet connection (transport layer security (SSL)). This prevents unauthorised third parties from accessing the content of the communication. 

You can prevent the use of these cookies by making the appropriate settings in your browser. In that case, the chat function will not be available. The chat function can be terminated at any time by closing the chat window.

Data of UK and EU residents is stored by tawk.to, Inc. on servers in the United States. We have entered into an agreement with tawk.to, Inc. to ensure that it treats personal data in accordance with the data protection regulations in force in the European Union, which we consider sufficient, as we expect limited personal data to be provided in the web chat.

Mailgun

We send automated emails such as for security notifications. We use Mailgun from Mailgun Technologies Inc., 112 E Pecan St. #1135, San Antonio, TX 78205. With regard to data processing in the USA, we note that we have signed an agreement with Mailgun Technologies Inc. to ensure that it processes personal data in accordance with the data protection regulations in force in the European Union, which we consider sufficient given the limited scope of the data transfer.



1.  Introduction

Purpose of this Policy

This Policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up for an account or purchase an insurance policy or another of our products or services.

This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy notice supplements the other notices and is not intended to override them. Controller Bewica Limited is the controller and responsible for your personal data (collectively referred to as ”Bewica”, “we”, “us” or “our” in this privacy notice).  

Our company details are: Bewica Limited, 44 Great Marlborough Street, London, W1F 7JL, Email address: [email protected] 

You also 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). 

Changes to the privacy notice and your duty to inform us of changes.

This version was last updated on 4 September 2019 and historic versions can be obtained by contacting us. 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 notice of every website you visit.

2.  The data we collect

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 follows:

To clarify, we expect the following information which we may collect not to be personal but business data unless you are a sole trader or (non-limited) partnership: 

We also collect, use and may share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does *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 notice.

We do not 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). Nor do we collect any 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3 How we collect personal data

We use different methods to collect data from and about you including through: