Privacy Policy  

 

The pages on this website are only directed at UK residents and comply with appropriate UK legislation and regulation. 

This privacy policy has been provided to let you know how we use and look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send to you. The policy also tells you about your privacy rights and how the law protects you when (i) we contact you, (ii) you contact us (iii) you visit our website. 

We promise to: 

  • Keep your data safe and private 
  • Give you ways to manage and review your marketing choices at any time 
  • Not sell your data to anyone else 

Data Controller 

The data controller is Neilson Place Limited who is authorised and regulated by the Financial Conduct Authority and entered on the Financial Services register www.fca.org.uk/firms/financial-services-register under reference (FRN) 971428 Neilson Place Limited. Registered in England and Wales. Number 12581962. Registered Office, 2 Windsor Dials, Arthur Road, Windsor SL4 1RS. 

Where data is provided to our partners in relation to a service you have requested, our partners may also act as data controllers. If you would like more information about how any of our partners process data, you should read the privacy policy for the relevant partner which will be available on the partner’s website. More information about this is set out under “Who we share your personal information with”. 

Data Protection Law 

We are conscious of our responsibilities as a “data controller” under the UK General Data Protection Regulation (UK GDPR) and we shall endeavour to ensure that the personal information we obtain and use will always be held, used, transferred and otherwise processed in accordance with that regulation and all other applicable data protection laws and regulations. Neilson Place Limited is registered with the Information Commissioner under registration number ZA755243. If you would like more information about our data protection policy, please contact us using the details shown on our website. 

How the Law Protects you 

Data Protection Law allows us to use personal information only if we have a clear reason to do so. This includes how we share data outside of Neilson Place Limited. To meet this requirement, we will only process personal data in the following circumstances: 

  • To fulfil and administer a contract we have with you; 
  • When it is in our legitimate interest; 
  • When we have a legal duty to; 
  • When you consent to it; 
  • When it is necessary for reasons of substantial public interest. 

There are circumstances where an alternative legal basis allows us to process personal data legitimately. Where we rely on an alternative legal basis for processing personal data, we will tell you what it is. 

How we use information about you 

We collect personal information from you when you contact us over the telephone or by email, when you complete application forms and when you access our website. We also collect personal information about you from third parties (more details can be found under the heading “Where we collect your personal information from”). We have provided examples below of the ways we may use your personal information and why. 

When/Where we collect and process your personal information  Legal Basis we can rely on to process personal information  Rationale 
When you call us or request to be called back  i) Legitimate Interest 

 

ii) Contract 

i) Contact initiated by you 

 

ii) Applies when you request a quote with a view to entering into a contract with us or to make changes to your existing policy 

When we call you to promote and sell our products  i) Consent 

 

ii) Legitimate interests 

We have evidence of your clear and unambiguous consent to be contacted 

When we can demonstrate an existing relationship with you and you have not objected to receiving our calls in the past directly or by registering with the Telephone Preference Service 

When we write to you to tell you about additional products and services.  i) Consent 

 

ii) Legitimate Interests 

You have given your agreement to Marketing 

To provide marketing that we think will be of interest to you 

To assess your eligibility for cover  i) Contract 

 

ii) Substantial Public Interest 

We need to obtain personal information to determine whether or not we are able to set up an insurance policy for you 

This may involve collecting information from you about your Health and Lifestyle Without this, we will not be able to proceed with an application for cover 

To deal with complaints and general feedback  Legal Obligation  To record and respond to complaints in line with regulatory requirements 
Transfer data to third parties  Contract  i) To enable our insurer partners to process your application and administer your insurance policy 

ii) To enable product providers to carry out checks to fulfil regulatory requirements to detect and prevent fraudulent activity 

iii) To enable providers of additional products, services or promotional offers you’ve asked for to provide these products, services or offers to you 

To contact you for the purposes of notifying you of any important information regarding your Policy or Mortgage.  i) Contract 

ii) Legitimate Interests 

i) To keep our records accurate and up to date 

ii) To update you regarding any changes being made to your insurance policy and to ensure your cover remains in place 

 

When you agree to take part in a questionnaire or survey  i)Consent 

ii) Explicit Consent 

i) from time to time, we may ask our customers to participate in a questionnaire or survey. We will only do so for legitimate business purposes, with your consent 

ii) The survey may ask you to provide us with sensitive data, such as information about your health. Where this is the case, we will gain your separate, clear and unambiguous consent. 

Data Analysis – Profiling: To develop and manage our brands, products and services by understanding our customers behaviours and preferences 

 

Legitimate interests  i) Defining target markets to which products are suited 

ii) Using our data to identify new audiences who are likely to want our products 

iii) Charging appropriately for products 

iv) Meeting genuine needs of customers through the products we provide 

 

Where we collect personal information from: 

Data you provide: 

  • when you apply for products and services 
  • when you talk to us on the phone 
  • when you use our websites 
  • in letters and emails 
  • social media 
  • When you participate in surveys and questionnaires 

We may also receive data from: 

  • third parties we work with 
  • companies that introduce you to us 
  • comparison websites 
  • third party professionals in relation to your application 

The categories of personal data we may obtain from third parties are: 

  • name 
  • gender 
  • contact details (email address and telephone number) 
  • birth date 
  • address and postcode 
  • Health and lifestyle information 
  • Employment & Income information 

 

When you provide us with personal data about others, you must (unless we agree otherwise): (a) inform the individual about the content of this Privacy Policy and any other applicable privacy notices provided to you; and (b) obtain their permission (where possible) to share their Personal Information with us in accordance with this Privacy Policy and other applicable privacy notices.  

Data we collect when you use our services 

  • Personal information that can help us identify you 
  • Personal information that can help us contact you 
  • Personal information to assess your application for an insurance product. This may include information about your health, categorised as “special category data”. We will only collect this data if the law allows us to do so 
  • Payment and transaction data – this includes credit or debit card details which we will pass on to relevant third-party suppliers, to pay for products or services you’ve received. Card details will not be retained once the payment has been made.  
  • Any profile you create or information you provide when you connect to our internet, mobile and telephone services, using cookies 

Who we share your personal information with? 

We may use and share your personal information with service suppliers and financial institutions who we partner with. This includes insurers and reinsurers when you apply for insurance through us. 

In all instances, our insurer partners will process your personal information for their legitimate business purposes, which includes: 

  • making decisions about whether to provide insurance and assistance services (such as claim assessment, claim processing and claim settlement); 
  • administering the policy, assessing and paying claims, and general customer service activities (including complaint resolution and claims disputes); 
  • detecting, investigating and preventing crime, including fraud and money laundering; 
  • carrying out market research and analysis; 
  • providing information about your policy in connection with any reinsurance; and 
  • complying with applicable laws and regulatory obligations (including laws and regulations outside of your country of residence). 

Where we share your data with insurance providers, they become data controller for the data they receive. Whenever our partners use your information for the above purposes personal data rights are considered carefully, and you have a right to opt-out of some of this processing. For more information on how to opt-out, please see the relevant partners’ privacy policy which can be found on each provider’s website.   

In addition, we may share your personal data with third parties we partner with, to provide you with additional products, services or promotional offers you have applied for.  

We may also share your personal information with legal and regulatory bodies such as the Financial Conduct Authority, the Financial Ombudsman Service and the Information Commissioner’s Office, to fulfil a legal or regulatory obligation, assist with an investigation, or demonstrate compliance. 

If we sell our company or part of it, we will share your information with the purchaser, who may then provide you with information on their products and services. 

We may transfer and process any personal information you provide to us to countries outside the European Economic Area. We will ensure that adequate safeguards are in place in connection with such transfer and that all necessary consent has been obtained. 

How we use your information to make automated decisions 

To assess your eligibility for cover we may use systems to make automated decisions based on personal information we collect from you. This involves us asking you to answer Health and Lifestyle questions when applying for a life insurance policy. These decisions may not involve human input, and the software and systems may apply predefined logic programming and criteria to make a decision and assess how we deal with you in connection with the provision of services. We will always hold this data safe and secure.  

 

You have the right not to be subject to a decision which is based solely on automated processing, to express your point of view and contest the automated decision. If you are not satisfied with the outcome of the decision returned following completion of the questionnaire, you may ask for this to be reviewed. 

If you choose not to give personal information 

We may need to collect personal information by law, or under the terms of a contract we have with you. 

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services you’ve requested from us. Any data collection that is optional will be made clear at the point of collection. 

Marketing 

We can only use your personal information to send you marketing messages to tell you about relevant products and services or offers that may be of interest to you if we have a valid reason to do so under data protection legislation. The two main reasons we rely on are where we have your consent, or if we have a legitimate interest to do so. 

When we rely on legitimate interests, we will issue you with marketing that we think will be of interest to you. We will only do this when we believe that your privacy rights do not override our legitimate interests and the processing will not cause unjustified harm to you. 

You can ask us to stop sending you marketing messages and update your choices by contacting us at any time. 

Whatever you choose, you will still receive important information relevant to your product, which could include changes to your existing products. 

How long we keep your personal information 

We maintain a data retention policy which governs how long we will keep your personal data for. We retain personal data about our customers and prospective customers. We will only keep your information for as long as reasonably required to demonstrate we have met our obligations to you and the rules that apply to us. 

We will keep your personal information for as long as you are a customer. After you stop being a customer, we will keep your data for up to 7 years for the following reasons: 

  • to respond to any questions or complaints 
  • to show that we treated you fairly 
  • to maintain records according to rules that apply to us 

We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons. If we do we will make sure that your privacy is protected. 

Your Rights 

Individuals have a number of rights in connection with their Personal Information. These rights only apply in certain circumstances and are subject to certain exemptions. These rights are noted below.  

All enquiries in respect of these rights will be handled by Neilson Place Limited, however, where necessary, we will liaise with other parties with whom we have shared your personal information (“Who we share your personal information with” above) when dealing with your request. 

How to get a copy of your personal information 

You can access the personal information we hold on you by contacting our Data Protection Officer. You can email or write to us by using the following details: 

Data Protection Officer at Neilson Place Limited, 2 Windsor Dials, Arthur Road, Windsor SL4 1RS, or email info@neilsonplace.com 

Letting us know if your personal information is incorrect 

You have the right to question any information we have about you that you think is wrong or incomplete. We will take reasonable steps to check its accuracy and correct it. 

If you want us to stop using your personal information 

You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using it if there is no need for us to keep it. This is known as the “right to object”, “right to erasure” or the “right to be forgotten”. 

However, there may be occasions when we will not be able to delete personal information if a legal or regulatory requirement prevents us from doing so. 

Restricting the use of your personal information 

You can ask us to restrict the use of your personal information if: 

  • it is not accurate 
  • it has been used unlawfully, however, you do not want it to be deleted 
  • it is not relevant anymore, but you request it is kept for use in legal claims 
  • you have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep it on using it. 

Data portability 

You can ask us to provide you with personal information you have given us, in a format that can be read by a computer. You can also ask that we share your data in this format, to someone else. 

How to withdraw your consent 

You can withdraw your consent at any time. Please contact us on 020 3800 1042 or email us at Support@neilsonplace.com,  if you wish to do so. 

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is the case, we will let you know. 

How to Complain 

Please contact our Data Protection Officer if you are unhappy with how we have used your personal information. To contact us about any of your rights set out in this Privacy Policy please write to the Data Protection Officer at Neilson Place Limited, 2 Windsor Dials, Arthur Road, Windsor SL4 1RS, or email info@neilsonplace.com. Please provide your full name, email address, date of birth and quote number or policy number when contacting us. 

You also have the right to complain to the Information Commissioner’s Office. 

The ICO’s address:             

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF 

Helpline number: 0303 123 1113 

ICO website: https://www.ico.org.uk