This notice explains how Caspian Insurance Services (referred to as ‘we’, ‘our’, ‘us’, etc.) may collect, use and process your personal information. By giving us your personal information you agree to us using that information as set out in this notice. For financial products and services we may also collect sensitive personal information about you, such as details about your health.

Caspian is committed to protecting your and your family’s personal information.

We may receive personal information about you, when you contact Caspian for example by doing any of the following:

• Requesting or obtaining a quote
• Purchasing a product from us or from one or our partners
• Using our Website
• Telephoning, texting, writing by post or email

What information do we collect?

The personal information we collect about you will vary depending on the financial product and/or service we provide to you. We collect personal information about you which may include:

• Name, date of birth, gender, marital status and contact details (including address, phone number and email address), proof of identity
• Details of your spouse or partner, a joint applicant, next of kin, dependants, designated beneficiaries or trustees
• Financial information (including income, expenditure, credit and bank details)
• Details of your professional advisers (including financial adviser(s), solicitors and estate agents)
• Employment details, including length of service, salary and tax details, place(s) and type of work undertaken
• Device IDs, IP addresses, cookie data, and location. A cookie is a small piece of text sent to your browser by a website that you visit. It helps the website to remember information about your visit, like your preferred language and other settings that can make your next visit easier and the site more useful to you. Cookies play an important role. Without them, using the web would be a much more frustrating experience
• Sensitive personal information such as health information (for example alcohol consumed, recreational drug use, tobacco use, current state of health, existing conditions, family or personal history in relation to some conditions

We will always be clear to explain when and why we need this information and the purposes for which we will use it and will obtain your explicit consent to use sensitive personal information:

• Details of your GP or other relevant medical consultants
• Details of the circumstances which give rise to a potential claim (which will include information we collect from third parties to verify such details)
• Any information you choose to give us from time to time

We may collect the personal information listed above from third parties, for example:

• Where the third party (e.g. your employer, a financial institution, your financial adviser or your landlord) holds that information
• To verify the information you have provided
• Or identity checking, fraud and crime prevention services
• If you make a complaint, details of that complaint and relevant information from the regulator you have complained to; and information we need to meet our legal and regulatory obligations
• This notice also applies to any personal information you give us about anyone else. If you disclose personal information about someone else, you must ensure you have their permission to do so and that they understand the information set out in this notice

What do we use your information for?

We use your personal information:

• To improve the quality of our services and develop new ones
• To respond to your enquiries about financial products and/or services
• To assess and process your application(s) for financial products
• To provide you with information about products and/or services (unless you tell us not to, see below for more details) and for advertising, public relations and business development in connection with our customers
• To manage and administer your financial products and/or services, claims and our wider relationship with you
• For arrears and debt collection
• For research (including market research), anonymisation and analysis (including statistical analysis and customer profiling)
• As otherwise legally required or lawfully permitted under the Data Protection Act, including meeting our regulatory, legal and good governance obligations
• For the prevention or detection of crime (including fraud); and as otherwise notified to you by us from time to time

Data retention periods

When processing your policy sale, you gave Caspian explicit consent to process and retain your sensitive information to assist you during the lifetime of your policy. You also give consent for Caspian to use this for marketing and statistical analysis. The data is held encrypted on secure international servers for this purpose.

Should your policy expire we will erase your data after a period of six years. All our customer data is held in line with EU and UK General Data Protection Rules. Should you wish to revoke your consents. Please contact us for assistance.

Who may we share your information with?

We may share your information with:

• Our administrators, service providers and reinsurers for the day to day provision of our financial products and/or services
• Service providers, other insurers, guarantors, government and industry bodies; for example, HMRC, ABI, regulatory authorities, fraud and crime prevention organisations and law enforcement agencies
• Other Caspian Group companies for the purposes set out in this notice
• Any companies or people that we might in the future sell, or consider selling, our business or part of our business to
• Third parties who operate services to allow you to review, evaluate and obtain financial products and/or services and who allow us
• Search for policies and assets
• Any trustees of your policy
• Anyone you ask to act on your behalf

Our administrators, service providers and reinsurers may also share your information in the ways set out above in order to meet their regulatory and legal obligations.

Where we send your information

We operate primarily in the United Kingdom. However, sometimes we will process your personal information in other countries including those outside of the European Economic Area. Where this happens, we take care to ensure that this processing is carried out by organisations on terms which safeguard the security of your personal information.

Your rights

You have the right to ask:

• What information we hold about you. If you would like details of the information we hold about you, just contact us
• Why we have it
• How long we will keep it
• Where we got it from
• Details of any automated decision-making
• For any inaccuracies in the information we hold about you to be corrected
• To have your details erased “the right to be forgotten”
• If you would prefer not to receive marketing information from us or selected third parties, please contact us using the details provided
• To revoke your consents at any time

If you have any question’s such as the above please contact: The Data Controller, Data Protection Office, Caspian Insurances Services, Norfolk House, 7 Norfolk Street, Manchester, M2 1DW.

If you remain dissatisfied once you have contacted us regarding your data or consents you can raise the issue to the Information Commissioner’s Office Website: https://ico.org.uk/concerns/handling

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time for example, to keep it up to date or to comply with legal requirements. We will not reduce your rights under this Privacy Policy without your explicit consent. You should regularly check this Privacy Policy for updates. If there will be any significant changes made to the use of your personal information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our website.