Who are we?
We are Global Life Distribution (UK) Ltd (“GLD”), trading as Promis Life. Throughout this document, when we use the terms “we” or “us” or “our” we are referring to GLD. When we talk about our partners in this document we mean organisations that we have a relationship with and whom we trust to collect and/or store personal information about you on our behalf.
If you have questions or concerns about your privacy and how we maintain it you can contact us at: Freepost Promis Life (no stamp required if posted in the UK), Phone: 0800 907 0796, Email: firstname.lastname@example.org
What personal information do we collect?
We collect information from you via our website, partner websites, telephone calls or when you send us your details. When you interact with us we collect personal information from you. This will usually be your name, address, gender, date of birth and at least one telephone number to call you on.
If you decide to purchase a policy, we will collect your bank account details so that our insurance partner (iptiQ Life S.A., “iptiQ”) can deduct payment of your insurance premiums, and we will also ask about your occupation for regulatory purposes.
We record every phone call we make or receive for customer service and regulatory reasons, so any personal information you give us on a call is also collected.
Why do we collect your personal information?
If you give us your consent or we believe that you expect us to contact you, we may use your personal information to provide you with information about our products. We may contact you by telephone, SMS, post or email.
Providing a Quote
To give you an accurate quote we need to know your date of birth (or the date of birth of the person you want to insure). We will provide you with a quote on the website, telephone or in the post.
If you purchase one of our products we will pass on some of the personal information we collect about you to iptiQ. They will use this information to:
Legal rules and regulations
We will collect some personal information from you to adhere to certain legal rules and regulations. We will also keep some of the personal information you give us to be certain we are meeting legal requirements – covering the rules of contract law and all regulations we must follow as required by the Financial Conduct Authority (“FCA”), Ofcom and the Information Commissioner’s Office (“ICO”).
Understanding our customers
In order to improve our services we sometimes conduct analysis on the information we collect to look for trends in the profile and behaviour of our customers. This allows us to understand what our customers want and need. We also conduct customer surveys and/or market research to understand what our customers think about the products and services we provide.
Why can we use your personal information?
We rely on 4 of the legal reasons in the data protection regulation to allow us to collect and use your personal information – “consent”, “legitimate interest”, “creating a contract” and “legal obligations”.
You do not have to give your consent and you have the right to withdraw your consent at any time.
Sometimes we may use your personal information because we believe you expect us to contact you with information about our products or provide you better service, such as:
At any time you can ask us not to contact you.
Creating a Contract
When you buy a life insurance policy from us you are entering into a contract with our insurance partner, iptiQ. To set up the contract correctly we must collect personal information from you and share it with iptiQ. If you ask us not to collect or pass on this information we will be unable to sell you a product.
There are specific regulations for selling insurance products via the telephone and internet. We are also regulated by the FCA, and comply with the ICO and Ofcom rules and regulations. To prove that we comply we have to collect and store some of the personal information you give us, such as on telephone call recordings so any regulator can ensure we give our customers accurate and honest information.
As a regulated business we must meet our legal obligations and this means you cannot request we do not collect and use personal information that is required for those purposes.
Who might we give your personal information to?
We will not pass on your information to other companies so they can market to you.
We may share your personal information with trusted partners. The three main organisations we share your personal information with are our insurance partner iptiQ, our mailing company Pepper Communications Ltd. and our call centre partner Customer Experience People Ltd.
Sometimes we may share your information with other companies to help us analyse and better understand our customers including for customer profiling, to conduct customer surveys or market research or for customer reward fullfilment. If we do share it, we will ensure the company follows all the necessary regulations.
We may also share some personal information with social media companies so that they can match this to what they already have themselves. This will help them display relevant advertisements to you and others about our products and services. Social media companies that provide services for us may include Facebook, Instagram, WhatsApp, Google, YouTube and Twitter. If you do not want us to share your personal data with these companies for this purpose, you can tell us not to, by emailing us at email@example.com or calling 0800 907 0796 to update your details or marketing preferences.
Where do we store your personal information?
We store and access your personal information within the United Kingdom and/or European Union (“EU”). Very occasionally, there may be operational requirements to transfer your data outside the EU. If we do this, the same degree of protection is given to your personal information as if it were being stored and used within the EU. We will check that any organisation that collects or holds your personal information on our behalf also stores it in the EU. If they do not do that we will check they take the necessary steps to make certain your personal information is treated in the same way as if it was in the EU and regulated under its laws.
What rights do you have?
You can ask that we stop contacting you.
You can ask to see the personal information we hold about you.
You can ask us to correct inaccurate personal information that we hold about you.
You can ask to erase some of your personal information.
You can ask to move some of your personal information to another provider.
You can complain to the ICO
If you have a concern about the way we have handled your personal information you can make a complaint to the ICO by contacting them through their website (www.ico.org.uk/concerns) or calling them on 0303 123 1113.
How do we protect your personal information?
To keep your personal information safe we store it using industry-standard encryption and information security policies. This means your information is only accessible to our staff who are authorized to do so, and only from within our offices or other approved locations. If we have to transmit your information to any of our partners, appropriate security measures are in place to prevent it from being intercepted.
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