Bewica respects your privacy and is committed to protecting your personal data. This Privacy & Cookie Policy (“Policy”) sets out how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.

1. Introduction

Purpose of this Policy

This Policy aims to give you information on how Bewica collects and processes 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 other Bewica product or service.

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 17 September 2018 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:

  1. Identity Data includes title, first name, last name, username or similar identifier.
  2. Contact Data includes email address, telephone numbers and address (where this is not business data).
  3. 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.
  4. Profile Data includes your username and password, feedback and survey responses.
  5. Usage Data includes information about how you use our website, products and services.
  6. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  7. Cyber Security Data about your company’s cyber security which you may share with us or we obtain from third parties. This may be business rather than personal data (where this is not business data)
  8. Financial Data includes, bank account and payment card details (where this is not business data).
  9. Transaction data includes details about payments to and from you and other details of products and services you have purchased from us, where this is not business data. If applicable, this also includes questions you ask us (eg via email or web chat)
    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:
    • contact address
    • bank account or payment details
    • transaction data (details about payments to and from you and other details of products and services you have purchased from us)
    • cyber security data about your company
    • information about your company’s cyber security which you share with us or we obtain from third party sources.
    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:

1. Direct interactions. You may give us your Identity, Contact, Profile, Cyber Security, Marketing & Communications and Financial Data by filling in forms or by corresponding with us by post, phone, email, web chat or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
2. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. See below in the section ‘Cookies’ for additional details on these.

3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

4. Technical and cyber security data from:
(a) analytics providers such as Google based outside the EU;
(b) search information providers such as Google based outside the EU;
(C) cyber security data from specialist players like HaveIBeenPwned (haveibeenpwned.com) based outside the EU.

5. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.

6. Identity and Contact Data from data brokers or aggregators* (not yet in place).

7. Identity and Contact Data from publicly available sources such as Companies House based inside the EU.

4. How we use personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal information. In any exception, for example if we need your consent for a product or service or using your data for a different purpose from which it was collected, you will be asked to provide consent before at the time and you will always have the right to withdraw consent by contacting us via the contact details indicated on our site.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of 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.

Privacy-Policy-Picture-of-Data-Use-Table

Promotional offers from us
We may use your Identity, Contact, Technical, Usage, Cyber Security and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you created an online account or signed-up for a newsletter and, in each case, you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside Bewica for marketing purposes. In that case you will have the option to opt-out.

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 (see details on our homepage).

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.

5. How we share personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary at the end of this document.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• 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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Our data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In 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.

8. Our data retention approach - How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We keep basic information about our customers who have purchased a service from us (including Contact, Identity, Financial and Transaction Data) for up to seven years after they cease being customers for tax and regulatory purposes.

We may keep information about our other customers for up to two years after they cease being customers.

In some circumstances you can ask us to delete your data: see request erasure in ‘9. Your Legal Rights’ below for further information.

In some circumstances we may 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.

9. Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

- 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
If you wish to exercise any of the rights set out above, please contact us at [email protected] .

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this policy
We may amend this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. If we make changes in the way we use personal data, we will notify you by posting an announcement on our Services or sending you an email. Users are bound by any changes to the Policy when he or she uses the Services after such changes have been first posted.

Questions or concerns
If you have any questions or concerns regarding policy in connection with our platform and services, please send us a detailed message to our Data Protection Officer. We will make every effort to resolve your concerns. If your questions or concerns are not answered online, you may write to us at Bewica Limited, 44 Great Marlborough Street, London, W1F 7JL, Email address: [email protected]

10. Cookies
Our site (like most platforms) uses cookies and other similar technology such as ‘web beacons’.

What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website or mobile application. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognises the cookies. You can find out more information about cookies at www.allaboutcookies.org.
Cookies are widely used in order to make sites work, or to work more efficiently, as well as to provide information to owners of the platform.
We use cookies to enhance the online experience of our visitors (for example, by remembering your language and/or product preferences) and to better understand how our site is used. Cookies may tell us, for example, whether you have visited our site before or whether you are a new visitor. They can also help to ensure that any adverts you see online are more relevant to you and your interests.

Types of Cookies
There are two broad categories of cookies:
First party cookies, served directly by Bewica Limited to your computer or mobile device. They are used only by Bewica Limited to recognise your computer or mobile device when it revisits our site.
Third party cookies, which are served by a service provider on our site, and can be used by the service provider to recognise your computer or mobile device when it visits other sites. Third party cookies are most commonly used for platform analytics or advertising purposes.
Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are ‘permanent cookies’, meaning that they survive after your browser is closed. They can be used by the site to recognise our computer or mobile device when you open your browser and browse the internet again.

What cookies do we use?
Our site uses the following types of cookies:

Privacy_Policy_Cookies_Table

How to control or delete cookies
You have the right to choose whether or not to accept cookies and we have explained how you can exercise this right in the section ‘How to edit, delete or access your personal data’ (which applies to all personal data, including cookies). However, please note that if you do not accept our cookies, you may experience some inconvenience in your use of our site.
You can set your cookie preferences by changing your browser settings so that cookies from this site cannot be placed on your computer or mobile device. In order to do this, follow the instructions provided by your browser (usually located within the ‘help’. ‘tools’ or ‘edit’ facility).
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

Pixel Tags
We may also use pixel tags (which are known as web beacons and clear GIFs) on our site to track the actions of users on our site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the site, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

IP Addresses
We may collect information about your computer or mobile device, including where available your IP address, operating system, log in times and browser type. We use this information to better understand how visitors use our site, for internal reporting purposes and to provide and improve our products and services. We may anonymise and share this information with advertisers, sponsors, and/or other businesses.

11. Glossary
1. Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected]

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

2. External third parties
• Service providers acting as processors based in the EU and the US who provide cloud hosting and payment processing services. Where processors are based in the US, they have certified to the EU-US and Swiss-US Privacy Shield.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK or EU who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Additional third parties may be added in the future.