- this website
- Creating an online account
- Mobile device and applications (“Apps”)
- Social media
The purpose of this policy is to explain how we use any personal information we collect about you, the choices you have about how we use that information, the choices you have regarding our communications with you and the marketing offers that you want to be sent.
By using any of Courtiers’ online services, you are accepting and consenting to the practices described in this policy. You can withdraw consent at any time by contacting us using the contact details listed below.
For the purpose of data protection legislation, Courtiers is considered to be a Data Controller in respect of your personal data.
Courtiers can only use your personal information if we have a lawful reason to do so. The GDPR provides 6 reasons under which we can use your personal data:
- When you have consented to us processing your personal information for a specific purpose.
- When it is necessary to provide the product or service requested.
- When it is our legal duty to do so, e.g. keeping records of transactions to comply with financial laws.
- When it is in your vital interest.
- When it is necessary for us to perform a task in the public interest.
- When it is in the legitimate interest of Courtiers or a third party to do so, e.g. sending relevant communications about new products and services.
We may collect and process the following data about you:
Information that we collect from you: this is information that you voluntarily provide to us by accessing our website, filling in forms, register for an online valuation account, email notifications and/or newsletters. This information may include, but is not limited to, your name, address, e-mail address and marketing preferences.
Your personal data may be used by any company within the Courtiers group in the UK. We may use your information in the following ways and for the following purposes:
- To help us to monitor, analyse and improve our online services.
- To provide you with information that may be of interest to you, such as our newsletters and articles.
- To market services to you.
- To notify you about changes to our services or products.
- To measure and understand the effectiveness of the content on our website and that sent to you by email, to ensure that the content is well-presented and relevant and to inform future content.
- For Courtiers’ administration purposes, such as data analysis and research.
- To assist in keeping our website and our systems secure and to prevent money laundering and other financial crimes.
- To enable Courtiers to comply with industry standards and regulatory and statutory requirements.
- If you do not wish us to collect and use your personal information in these ways, it may mean that we are unable to provide you with our products and/or services.
We do not use fully automated decision-making. We may, however, process your data on a partially automated basis in order to identify certain characteristics of yours (profiling) in order to provide you with target-appropriate communications, information and advice.
The length of time over which we hold your personal data will vary and the retention period will be determined by a number of factors, including the purpose for which we are processing your data and any legal or regulatory obligations that may impose a minimum retention period.
Information that is no longer needed will be securely destroyed, encrypted or anonymised (i.e. can no longer be identified as being your personal data).
Courtiers may share your personal data with third parties outside of the Courtiers group, such as with our IT and communications providers and electronic data storage services. With regard to current clients for whom we hold additional information to that collected from our online services, your personal data may also be shared and processed by our associated companies, product providers, auditors, introducers and insurers, as detailed in our Client Agreement.
Courtiers requires all third parties to process your personal data in a manner compliant with the requirements of data protection legislation.
We may also share your information with regulatory or legal bodies in the UK or overseas in order to comply with any legal and regulatory requirements.
Whenever we share information, we do so in line with our obligations to keep that information safe and secure.
You have rights as an individual which you can exercise in relation to the information we hold about you. Those rights include:
- the right to ask us what information we hold about you and obtain information regarding the processing of your personal data;
- the right to request a copy of the information we hold about you;
- the right to ask us to rectify/amend your personal data if it is inaccurate or incomplete;
- the right to request that we erase your personal data. Please note that there are some circumstances in which we will decline such a request, for example where we are obliged to retain the information for overriding regulatory, contractual or health and safety purposes (exclusions are listed in Article 17(3) of the General Data Protection Regulations);
- the right to request that we restrict our processing of your personal data if you are concerned about the accuracy of the information or if you believe we are not doing so lawfully;
- the right to request that we send your personal data in electronic format to another data controller where this is technically feasibly possible. Please note that this right only applies to information that you have provided to us;
- the right to object to us processing your personal data in certain circumstances. There may be some circumstances in which we have the right to refuse that request.
If you would like to exercise any of the rights listed above, you should direct any such request to Courtiers in writing to our registered office address listed in the ‘Who Are We’ section above.
We take information and system security very seriously and take appropriate technical and organisational measures to manage risk to the confidentiality, integrity and availability of your Personal Data. Any personal information which is collected, recorded and processed by Courtiers, whether paper copies or digital copies, will be treated in confidence and will have appropriate safeguards to protect that information against any unauthorised or accidental disclosure, access or deletion.
Courtiers’ data is held at two secure server sites in the UK. Courtiers does not store any Personal Data outside the European Economic Area (EEA).
Where personal data is transferred to, and stored at, a destination outside the European Economic Area (“EEA”), Courtiers will take all steps reasonably necessary to ensure that your data is treated securely and provided with an equivalent level of security as would be applied by UK / EEA data privacy laws (such as with the EU-US Privacy Shield scheme).
Where you have provided the appropriate permissions, we may from time to time contact you by email with information and articles (including those about products and services) which may be of interest to you.
If at any point you would like to opt-out of receiving marketing communications from us, please click on the unsubscribe link at the bottom of any emails you receive. Alternatively, you can contact us, stating your preferences, using the contact details listed in the ‘Who Are We’ section above.
If you are not satisfied with our response or you still have a complaint about our use of your information, you can contact the Information Commissioner’s Office via their website or write to them at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.