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- Who are we?
- Van Insurance
- How do we collect your personal information?
- What personal information do we collect about you?
- How do we use your personal information?
- Purposes for which we use your personal information
- How long do we keep your personal information for?
- Who do we share your personal information with?
- Automated Decision Making
- What are your legal rights?
- Is your personal information transferred outside the EEA?
- Data Security
- Complaints and contact details of our data protection officer
1. Who are we?
We (Digitonomy Limited) are a credit broker and insurance intermediary, and we are authorised and regulated by the Financial Conduct Authority (FRN 690249). Businesscomparison.com is one of our trading styles, and we host the businesscomparison.com website. We are based in Chester, and our registered office is at the Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN. Our registered company number is 08385135. We are registered with the Information Commissioner's Office with registration number ZA007309.
"Personal information" in this policy means any information that we collect that could identify you such as for e.g. your name, address and online identifiers like your IP address.
3. Van Insurance
We work with Trade Direct Insurance Services Limited ("Trade Direct"), who trade as Small Business Direct to provide van insurance, and you can purchase it through our website.
- We are a data controller in relation to the personal information you give to us on this website and we store it in a UK data centre.
- Your personal information will be used to create an account when you use our website. Any quotes that are generated for you will be saved here. You can update the personal information in your account and delete any of the quotes saved there at any time.
- We share the information you provide with Trade Direct who provide quotes for our van insurance and who fulfil and administer the policy.
- Trade Direct will review your information to carry out an initial assessment. This may involve checks with fraud prevention and credit reference agencies to assess your insurance risk, verify your identity, help prevent fraud in order to provide you with the best premium and payment option possible. If Trade Direct carry out these checks, it will involve an automated decision being made about you, known as a quotation or soft search. Please see section 10 for more information about this and what rights you may have as a result.
- Trade Direct are a separate data controller when they receive and process your information in this way.
- If Trade Direct are able to provide you with a quote(s), this will be displayed on our businesscomparison.com website so that you can choose the most suitable option. When proceeding with a quote, you will be directed to Trade Direct’s website to complete your purchase.
- Trade Direct will review the information provided to them to assess whether they are able to provide you with van insurance. If successful, they will then process your personal information for the purposes of fulfilling and administering your van insurance policy.
- We will stay in contact with you about your search for van insurance and the quotes that you have received, (unless you have asked us not to) using the contact details you have given to us.
- We will also contact you (providing you have consented to this) about any of our other products and services.
4. How do we collect your personal information?
We collect personal information from you in the following ways:
4.1 Information you give us:
- Information you give us when you complete any online forms on our website to search for a quote(s) for van insurance and to purchase a policy.
- Information you provide when corresponding with us by phone, email or other means. This includes information you might give us when you search for a quote(s) for van insurance, if you purchase a policy, or if you need to ask us a question, report a problem with our site or if you otherwise contact us.
4.2 Information we collect from you:
5. What Personal information do we collect about you?
If you use our website to search for a quote(s) for van insurance and/or to purchase a policy, we will need to collect the following personal information about you:
Identity information: this includes your first and last name, and your date of birth.
Contact information: this includes your address; telephone number(s), and your email address.
Employment information: this includes your employment status; the name of your employer; your job title, and the time you have been in your current job.
Motoring Offences: this includes any endorsements and penalty points on your driver record. You can view your driving licence record at https://www.gov.uk/view-driving-licence to see what penalty points you have and when they will be removed.
General information: this includes your home owner status, your marital status and the number of any dependents you may have.
Marketing and communications information: this includes your preferences in receiving marketing from us and your communication preferences.
Technical information: this includes your internet protocol (IP) address used to connect your computer to the internet; your browser; time zone setting; your operating system and platform; the source of your enquiry (for example Google, Facebook, Bing etc) and the device that you are using. We also collect information about your visit to our site including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including the date and time); page response times; download errors; lengths of visits to certain pages; page interaction information (such as scrolling; clicks and mouse-overs); methods used to browse away from the page, and, if you linked to our site from a search engine, the address of that search engine and the search term you used.
Please note: it is your responsibility to check and ensure that any information you provide is correct, complete and accurate. If you fail to provide your personal information where requested, you may not be able to complete your purchase.
6. How do we use your personal information?
We will only collect and use your personal information when the law allows us to. Most commonly, we will use it in the following circumstances:
Where it is necessary for our legitimate Interests (or those of a third party): we may process your personal information for the legitimate interests of our business (or those of a third party) in providing you with a quote(s) for van insurance and enabling you to purchase a policy, providing these interests do not override your privacy in any way. Our legitimate interests for processing your personal information are:
- The interests of our company in conducting, managing and improving our business. This includes enabling you to search for a quote(s) for van insurance and/or purchase a policy, and contacting you with that information by telephone call, email, SMS or automated message. (This contact won’t include marketing communications about other products and services unless you have given us your consent to receive these communications.) Using your personal information in this way is an essential part of us being able to provide our service to you.
- To enable us to communicate with you about any of our related products and services, (unless you have asked us not to), using the contact details you have given to us. (Our right to do this is known as the “soft opt-in.” This is explained in more detail below.)
- To improve the services, we provide. To achieve this, we will use your personal information to customise certain features of the services we provide and for market research purposes. We are dedicated to constantly finding ways to improve our business and using your personal information in these ways enables us to achieve this.
Consent: Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you via digital channels such as email or text message. Depending on the situation, we will ask for this via an opt-in or soft-opt-in, (explained below.) You have the right to withdraw consent to marketing at any time by contacting us.
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by using our website to search for a quote for van insurance), and we are marketing other similar services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most customers, this is beneficial as it allows us to tell you about other related products and services that we think would be useful to you alongside the specific one you originally expressed an interest in applying for.
Marketing: we will only contact you in response to a request or communication from you, under the soft opt-in, or where you have given us your consent to contact you by sms, email and/or telephone. We will not send unsolicited marketing communications to you about any other types of products or services.
Third-party marketing: we will not share your personal information with any company outside our company for their marketing purposes unless you give us your consent to do this.
Change of purpose: we will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Where we need to comply with a legal or regulatory obligation: we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Purposes for which we use your personal information
We have set out below, in a table format, a description of the ways your personal information could be used by us, and which of the legal bases we rely on to do so. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To enable you to search for a quote(s) for van insurance and/or purchase a policy and to submit your information to Trade Direct.
(c) Motoring Offences
Necessary for our legitimate interests (to operate our business in providing and improving the service we provide as an insurance intermediary.)
To enable you to create an account to retrieve your van insurance quotes that have been saved for you.
(c) Motoring Offences
Necessary for our legitimate interests (to operate our business in providing and improving the service we provide as an insurance intermediary.)
To enable us to communicate with you:
(a) About your search for van insurance, and any of our similar products and services (unless you have asked us not to) using the contact details you have given to us.
(b) for marketing purposes to tell you about our other products and services, (either from us or other companies), that we think may be interesting to you. If you agree, and depending on your contact preferences, this will be by telephone, sms, email and/or automated message in order to give you information about business loans, business energy, business banking, asset finance, invoice finance and commercial mortgages.
(c) by sending you our newsletter by email if you have agreed for us to do this.
(d) about any enquiries or complaints, you may have.
(e) to ask you to complete a survey or provide us with feedback, testimonials or reviews
(c) Marketing and communications information
(d) Motoring Offences
(a) Necessary for our legitimate interests (to operate our business in providing and improving the service we provide as an insurance intermediary, by remaining in contact with you about your search and our similar products and services.)
(b) Your Consent
(c) Necessary to comply with a legal obligation
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer, improve and protect our business and this website (including training, troubleshooting, data analysis, testing, system maintenance, research, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to improve our marketing strategy)
8. How long do we keep your personal information for?
Unless required by law to keep your personal information for a different period of time, we will keep it for no longer than 12 months from the date you used our website to search for van insurance or until you ask us to delete it. Please note that if you ask us to delete your personal information it may still remain on our backup systems for legal or other regulatory reasons.
9. Who do we share your personal information with?
When you use our website to search for van insurance, your information will be shared with the following third parties:
- Trade Direct who provide quotes for our van insurance and who fulfil and administer the policy.
- Other companies who enable us to provide our services as an insurance intermediary or who provide services to us, for example IT Service Providers (who provide for e.g. technology platforms or other IT services including data storage), and Communication providers (who provide for e.g. email and text services for customer contact and marketing purposes).
- Advertising networks and social media companies such as Instagram, Facebook, Google and SnapChat so that we can present you with relevant advertisements.
These third parties help us to provide our services as an insurance intermediary. In order that they can do this, we may need to let them process your personal information. Where relevant, we will make sure that they keep the information secure and in accordance with our instructions, the General Data Protection Regulation 2016 (“GDPR”) and other UK privacy legislation.
We will also share your personal information when we have your consent, or where we are obliged to do so for a legal or regulatory reason, for e.g. to prevent or detect crime, for compliance monitoring or to enforce or apply our Terms and Conditions and other agreements.
10. Automated Decision Making
An automated decision is one where a computer or system is used to assess the information you provide to make a decision about you. We do not make automated decisions about you, however, Trade Direct may do this when we share your personal information with them so that they can carry out an initial assessment (for e.g. a soft search) before providing you with van insurance quotes.
(Note: a “soft” credit search helps an organisation to decide whether or not they may be able to provide you with insurance. Unlike a “hard” credit search, a soft search is recorded on your credit file, but only you rather than any other organisation will be able to see it. A soft search does not therefore affect your credit rating.)
As a result, you have the right to ask Trade Direct that they do not make a final decision based solely on automated means. You can also object to the automated decision and ask that a person reviews it. To exercise this right, you will then need to contact Trade Direct directly.
11. What are your legal rights?
- Right to withdraw consent - if you have consented to us sending you information about other products and services (for example: business loans, business energy, business banking, asset finance, invoice finance and commercial mortgages), either from us or other companies, you have the right to withdraw your consent at any time. You can do this by sending an email by using our contact us form, or by writing to the Customer Services Manager at: Businesscomparison.com, Digitonomy Limited, Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN. We will action any request you make promptly, although it may take a short time for this to be processed through our systems.
- Right to Object - because you have asked us to help you find van insurance, we need to process the personal information you give us to enable us to do this. You can object to this processing at any time by sending an email by using our contact us form, or by writing to the Customer Services Manager at Businesscomparison.com, Digitonomy Limited, Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN. We will action any request you make promptly, although this will mean that we will not be able to help you find the van insurance that you asked us to search for.
- Right of Access - you can ask us at any time to confirm whether we hold your personal information, and if so you can access it by writing to us at: Data Subject Access Request Department, Businesscomparison.com, Digitonomy Limited, Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN or by sending an email by using our contact us form.
- Right to rectification - if we hold personal information about you that is inaccurate, you can ask us to correct it, and we will do this as quickly as possible.
- Right to erasure – if you have provided us with consent to process your personal information or if it is no longer necessary for us to hold your personal information bearing in mind the reason why you provided it to us, you can ask us to delete it. If you ask us to do this, we will delete your personal information as soon as possible although this will mean that we may not be able to help you find the financial product or service that you asked us to search for.
- Right to restrict our use of your information - you can ask us to restrict our processing of your personal information if you think for example that the personal information you gave us is inaccurate. This may mean that you are unable to complete your search for van insurance.
- Right to complain to the Information Commissioner’s Office (ICO) - we will try to resolve any complaint that you may have in relation to data protection issues. If you are not happy with our final response you have the right to have your complaint dealt with by the ICO. Details of how you can do this are in section 12 - "Complaints and contact details of our data protection officer."
12. Is your personal information transferred outside the European Economic Area (“EEA”)?
Although we do not routinely transfer personal information outside the UK, we may sometimes need to do this where any of our third-party suppliers are either based outside the EEA, or where they use data processors based outside the EEA. Where this is the case, we will make sure that they agree to: keep your personal information secure; apply the same levels of protection as we are required to apply to information held in the UK, and to use it only for the purpose of your search for van insurance. We will do this by putting in place appropriate safeguards and protections as stated under UK law, for example using a data-transfer agreement incorporating certain standard model protection clauses.
13. Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information 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.
14. Complaints and contact details for our data protection officer
We want you to be confident that we are handling your personal information responsibly and in line with good practice. If you are concerned that we are not doing this, you should contact us immediately. We will treat your concern seriously and work with you to try and resolve it.
Please address your correspondence to:
The Data Protection Officer
The Steam Mill Business Centre
Steam Mill Street
Last updated 25/05/2018