DATA PRIVACY NOTICE

We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document.

Who we are

Quote Me Simple Ltd collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.

When we mention “Quote Me Simple”, “QMS”, “we“, “us” or “our” we are referring to Quote Me Simple Ltd.

We provide you with intermediary services in relation to financial products and services. 

The personal data we collect and use

In the course of our intermediary services we may collect the following personal data when you provide it to us:

• contact information

• identity information

• • Income information

• employment status

• lifestyle information

• health information
• details of any vulnerability
• details of your dependents and/or beneficiaries under a policy (If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below.)
• product/service details

Information collected from other sources

We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.

The personal data we obtain from other sources may include the following:

• From lenders and/or products/service providers:

• • Product/service details
  • details of any complaint about our services and/or the suitability of any advice we give you 

• From identification and verification checking agencies:

• • identity information
  • sanction check information if required

How we use your personal data

The below table sets out:

• how we use your personal data
• the lawful bases upon which we collect and use your personal data
• who we routinely share your personal data with (some of these third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’ below)

 

Rationale/Reason for Processing	Lawful Basis for Processing
to provide you with intermediary services to assist in the administration of any service you have obtained through us	Performance of a contract
to apply for service on your behalf	Performance of a contract
to manage complaints	Compliance with a legal obligation
to manage legal claims	Legitimate interests [– we have a legitimate interest in protecting ourselves from breaches of legal obligations owed to us and to defend ourselves from litigation.  This is needed to ensure that our legal rights and interests are managed appropriately]
making sure that all sales we make to you and advice we give to you are compliant with the rules and regulations that apply to financial services in the UK and with their policies and procedures	Compliance with a legal obligation
to obtain feedback from you on the service you have received from us	Legitimate interests [– we have a legitimate interest in operating our business.  This includes ensuring that the service we provide is of a satisfactory standard]
to retain records of any services or advice provided to you in accordance with our regulatory obligations	Compliance with a legal obligation
to retain records of any services or advice provided to you by your adviser in order to defend potential legal claims or complaints	Legitimate interests [– we have a legitimate interest in defending ourselves from legal claims and complaints.  This is needed to ensure that our legal rights and interests are managed appropriately]
to provide you with details of products and services from us and third parties that may be of interest to you in accordance with your preferences.  For more information see ‘Marketing’ below	Consent and legitimate interest
to detect, prevent and investigate fraudulent applications for products and services. to undertake investigations into allegations of misconduct and/or criminal offences to notify the relevant authorities of any suspicious activity following an investigation undertaken by us into allegations of misconduct and/or criminal offences	Compliance with a legal obligation. [We also consider that we have a legitimate interest in protecting ourselves, other parties and the financial services industry more widely in detecting, preventing and investigating financial crime and/or misconduct]
to undertake anti-money laundering, identification and verification checks, including assessment of your sanction check information (any personal data obtained for the purposes of meeting with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 will only be processed for the purposes of preventing money laundering or terrorist financing, unless the use of the data is permitted by or under another enactment other than those Regulations, or we have another lawful basis for processing it)	Compliance with a legal obligation
to evidence satisfaction of any request made by you in accordance with your rights under data protection regulation	Compliance with a legal obligation

Marketing

We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent and then have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us.

In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.

You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences please contact us:

By phone: 01204565158

By email: customerservices@quotemesimple.co.uk

By Post:  Quote Me Simple Ltd, All Souls Bolton, Astley Street, Bolton, BL1 8EY

In addition, you can opt out of receiving marketing at any time by clicking the ‘unsubscribe’ link at the bottom of every email. 

Cookies

Cookies are small pieces of data sent from a website and stored on a visitor’s browser. They are typically used to keep track of settings you’ve selected and actions taken on a site. 

There are two types of cookies:

Session (transient) cookies: These cookies are erased when you close your browser, and do not collect information from your computer. They typically store information in the form of a session identification that does not personally identify the user.
Persistent (permanent or stored) cookies: These cookies are stored on your hard drive until they expire (at a set expiration date) or until you delete them. These cookies are used to collect identifying information about the user, such as web surfing behavior or user preferences for a specific site. We collect information about your computer including the IP address, operating system and browser. This information also allows us to monitor general traffic patterns and usage of our website to help us to improve our website design and layout. Most browsers accept cookies automatically, but usually you can alter the settings of your browser to prevent automatic acceptance. If you choose not to accept cookies, you may not be able to use the full features of our website. 

The information within these cookies is anonymous. f you provide us with information about yourself by form filling on our website a session cookie collects that information and stores it during your browsing session so that if you wish to fill another of our forms, it will be automatically populated. Information stored in that cookie is deleted as soon as you terminate your browsing session.

Whether information has to be provided by you, and if so why

We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.

How long your personal data will be kept

We will hold your personal data for differing periods of time depending upon the reason we have for processing it. These retention periods are set out below. 

 

Type of Record	Retention Period
Customer file containing a record of any intermediary services provided by us	For as long as we reasonably consider that: we may need to deal with your queries you might legally bring a claim against us
Complaint file containing a record of any claim you have brought against us	For as long as we reasonably consider that you might legally bring an additional or repeat claim against us
Marketing lists	Based on the product or service between 4 and 6 years
Results of anti-money laundering, identification and verification checks, including assessment of your sanction check information	For as long as we are required/permitted to retain this personal data based upon our legal and regulatory obligations
Fraud and financial crime files	For as long as we reasonably consider that: we are required/ permitted to retain this personal data based upon our legal and regulatory obligations they may be required in the establishment, exercise or defence of legal claims
Records of satisfaction of any request made by you in accordance with your rights under data protection regulation	3 years from the date the request was satisfied

Your rights

You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:

• To access personal data
• To correct / erase personal data
• To restrict how we use personal data
• To object to how we use personal data
• To ask us to transfer personal data to another organisation
• To object to automated decisions
• To find out more about how we use personal data

We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.

We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive.  Where a fee is necessary, we will inform you before proceeding with your request.

We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests.  We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.  

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.

To access personal data

You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

To rectify / erase personal data

You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.

You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.

You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.

We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.  

To restrict our use of personal data

You can ask that we restrict our use of your personal data in certain circumstances, for example 

• where you think the information is inaccurate and we need to verify it; 
• where our use of your personal data is not lawful but you do not want us to erase it;
• where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
• where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.

We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.

To object to use of personal data 

You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.

To request a transfer of personal data 

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).

You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.

To contest decisions based on automatic decision making 

If we made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision making processes to protect your rights and freedoms.

[To obtain a copy of our safety measures for transfers outside of Europe

You can ask for a copy of, or reference to, the safeguards we have put in place when your personal data is transferred outside of the European Economic Area. We are not required to share details of these safeguards where sharing such details would affect our commercial position, or create a security risk.] 

You can contact us for more information

If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.

If you would like to exercise any of the above rights, please:

• email or write to our Data Privacy Manager at rahil@quotemesimplest.co.uk or Data Privacy Manager, :  Quote Me Simple Ltd, All Souls Bolton, Astley Street, Bolton, BL1 8EY
• let us have enough information to identify you, e.g. name, address, date of birth; 
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Our supervisory authority

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office (www.ico.org.uk).

We ask that you please attempt to resolve any issues with us before the ICO.

How to contact us

Please contact our Data Privacy Manager if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact our Data Privacy Manager, please send an email to rahil@quotemesimple.co.uk or write to Data Privacy Manager, Quote Me Simple Ltd, All Souls Bolton, Astley Street, Bolton, BL1 8EY