- We are Global Life Distribution (UK) Ltd, (“GLD”) and we control the personal information that you have given us.
- We may collect your name, address, gender, date of birth, telephone number, email address, the IP address of your computer, your occupation and your bank account details.
- We collect your personal information, including special category data such as health information which you may provide as part of the life insurance application process.
- We collect your information to communicate to you about our products, make decisions about your application for products, provide you with a quote, set up and administer your insurance policy, analyse customer behaviour and meet our legal obligations.
- Sometimes we work with companies who will collect or use your personal information on our behalf and pass that information to us. We always ensure this happens securely and that those companies use the same standards we apply to ourselves.
- We may share your information with iptiQ Life S.A. (our insurance partner), Pepper Communications Ltd. (our mailing house) and Customer Experience People Ltd (our call centre partner), and occasionally other trusted partners with whom we have contracts to allow us to deliver our service to you; for example, customer surveys, customer profiling and customer reward fulfilment partners.
- We will never pass on your information to any companies so they can market their products to you.
- We collect and use your personal information because either you have given your consent to do so, we have a legitimate interest to do so, we are setting up a contract for you, or to meet our legal obligations.
- You have rights in respect of the information that you give us – these include the right to see what information we hold about you and to ask that we erase some of the information.
- We take the collection and storage of your personal information seriously and have appropriate safeguards in place.
- If you have any questions or concerns, you can contact us at: Freepost Promis Life (no stamp required if mailed in the UK), Phone: 0800 907 0796, Email: email@example.com
- If you want to make a complaint to the Information Commissioner’s Office (ICO) you can contact them at: ico.org.uk/concerns or call 0303 123 1113
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.
We will collect information that allows our insurance partner, iptiQ to make decisions about your applications for insurance products we offer, this could include health and lifestyle questions.
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 underwriting and 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 collect personal information, which depending on the type of insurance policy could include special category data such as health information. This may also include personal information of the person you want to insure. Where possible 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:
- accurately set-up the product you have told us you want,
- send out your policy documents and some mail from time to time, and
- process any claim made on your policy.
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 better 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.
- We group and organise our customer information to help develop offers, products, and services to provide you with the best customer experience. This is known as marketing profiling
- We do not use profiling to make decisions about you which have legal or other significant effects
- If we profile your data, this might be shared with service providers who can then display advertisements to you and others about our products and services
- Personal information from customers can also be profiled to see how you use and interact with our website and online tools – improving the experience for everyone
- Profiling your data can also help us and our partners to make sure you do not get advertising if you’re already a customer – and keep things relevant
- We may use your data including email and phone number to build a profile of the type of customers we wish to reach – and may share this information with social media and digital companies. Some examples are given later in this privacy notice
Why can we use your personal information?
We rely on 5 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”, vital interests 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:
- When you provide your contact details in response to our advertising and indicate you are requesting information about our products and services.
- When you call us, if we are unavailable and you give your contact details to our messaging service.
- When you give us your personal information to get a quote for our products.
- When we need to contact you to clarify information we may have given you.
- When we conduct customer surveys or market research to improve our products and services.
- When we conduct profiling for the purposes of marketing to individuals
- When you agree to participate in customer research to help us better understand what our customers want and need.
At any time you can ask us not to contact you.
We may also use your personal information to meet our obligations to prevent or detect unlawful acts or prevent fraud.
Creating a Contract
When you buy a life insurance policy from us we rely on performance of a contract for the provision of a quote and with our insurance partner, iptiQ for the provision of the insurance contract. To set up the contract correctly we must collect personal information, including health and lifestyle 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.
Special category (sensitive) data
Depending on the type of insurance policy you want to purchase or obtain a quote for will determine the types of personal information we will need to collect to set this contract up correctly. This could include medical, health and lifestyle questions for the purposes of allowing us to provide you with an accurate quote and our insurance partner, iptiQ to underwrite, administer new and existing products, and deal with claims.
In certain circumstances we may need to share personal information to safeguard the vital interests of vulnerable individuals.
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. We are also required to meet regulatory and legislative obligations to prevent financial crime, report suspicion of terrorist financing or money laundering. 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 fulfilment. 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 take the security of your personal information very seriously. The personal information that we collect from you is stored and accessed within the United Kingdom (UK). For operational reasons the personal information that we collect from you may be transferred to and processed in a destination outside of the UK. It may also be processed by staff operating outside the UK who work for one of our trusted partners or suppliers. In these circumstances, your personal information will only be transferred on one of the following bases:
- To a country within the European Union (EU); or
- The country that we send the data is approved as providing an adequate level of protection; or
- The recipient has agreed with us standard contractual clauses approved by the Information Commissioner’ Office, obliging the recipient to safeguard the personal information; or
- There exists another situation where the transfer is permitted under applicable Data Protection Legislation.
To find out more about how your personal information is protected when it is transferred outside the UK, please contact our Data Protection Officer using the details above.
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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