Cookie & Privacy Policy

• 1. About us
     1. Purpose of this privacy notice

This privacy notice aims to give you information on how SPICE Framework collects and processes your personal data.

 

1. 1. 1. Controller

SPICE Framework is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

1. 1. 1. Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

1. 1. 1. Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

1. 2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1. 1. • Identity Data includes first name, maiden name, last name, marital status, title, gender and location data.
      • Contact Data includes address, email address and telephone numbers.
      • Financial Data includes bank account and payment card details.
      • Transaction Data includes details about payments to and from you;
      • Technical Data includes details of your visits to our website, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs). We also collect information about the device used to access the website, your internet protocol (IP) address, browser type and version, time zone, browser plug-ins types and versions, operating system and platform and other technology on the devices you use to access our website.
      • Marketing and Communications Data includes your communication preferences.

We do not collect any special category (sensitive) personal information, which includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, or criminal convictions and offences.

 

1. 1. 1. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

1. 1. How is your personal data collected?

We use different methods to collect data from and about you including through:

1. 1. • Direct interactions. You may give us your Identity, Contact and Financial Data by corresponding with us by post, phone, email, online, via contact forms or otherwise. This includes personal data you provide when you ask us to carry out our services for you.
      • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
      • Technical Data from analytics providers such as Google Analytics (although such data is anonymised to ensure that this information cannot be used to identify any individual);
      • Contact, Financial and Transaction Data from providers of technical, payment and delivery services and credit check providers;
      • Identity and Contact Data from publicly availably sources such as Companies House;
      • Social media platforms such as LinkedIn, Facebook, Instagram or Twitter.

 

1. 1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. 1. • Where we need to perform the contract we are about to enter into or have entered into with you.
      • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
      • Where we need to comply with a legal or regulatory obligation.

 

1. 1. 1. Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

We may use the personal data we hold about you in the following ways:

The reason we use your data	Our legal basis for its use
For the purposes of providing insurance, handling claims and any other related purposes – this may include underwriting decisions made via automated means.	For the performance of the contract between you and us.
For offering renewal, research or statistical purposes.	Our legitimate interests – for us to analyse historic activity, to improve our rating algorithms and to help predict future business impact. To further our commercial interests, to enhance our product offering and to develop new systems and processes.
To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.	Where you have provided consent.
To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.	Our legitimate interests – for us to analyse activity and traffic and for testing, research, statistical and survey purposes.
To notify you about changes to our service.	Our legal and regulatory obligations.
To safeguard against fraud and money laundering.	Our legal and regulatory obligations.
To meet general legal or regulatory obligations	Our legal and regulatory obligations.

 

You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.

 

1. 1. 1. Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of SPICE Framework for marketing purposes.

 

1. 1. 1. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of providing our services to you.

 

1. 1. 1. Cookies

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

There are three different types of cookies:

1. 1. 1. • Session cookies: these are mainly used by online shops and allow you to keep items in your basket when shopping online. These cookies expire when the browser is closed.
         • Permanent cookies: these remain in operation, even when you have closed the browser. They remember your login details and password so you don’t have to type them in every time you use the site. The law concerning permanent cookies stipulates that they need to be deleted after a period of six months.
         • Third-party cookies: these are installed by third parties with the aim of collecting certain information to carry out various research into behaviour, demographics etc.

 

1. 1. 1. 1. How we use cookies

This website uses cookies in order to function correctly and to gather technical information about the use of our website. This information is used for internal purposes only, such as quality control, to monitor Website performance, system administration and to evaluate usage of the Website, so that we can provide you with enhanced services and improve the Website for our customers.

 

Name	Retention Period	Description
_ga _ga*	2 Years	Used to distinguish users.
_gid	24 Hours	Used to distinguish users.
_gat _dc_gtm_*	1 Minute	Used to throttle request rate.

 

1. 1. 1. 1. Managing cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

The website aboutcookies.org provides information on how to manage your cookie settings and preferences depending on the browser type and version you use.

 

1. 1. 1. Change of purpose

We will only use your personal data 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

1. 1. Disclosures of your personal data
      • We routinely share data with:
      • our banks;
      • our insurers and brokers;
      • external service suppliers that we use to make our business more efficient,
      • HMRC and other regulatory bodies;

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In addition, we may share your data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

 

1. 1. International transfers

Personal data can be transferred, processed and stored within the European Economic Area (EEA) safely and securely as those countries offer an adequate level of protection to personal data in comparison to the UK. We do not transfer personal data outside of the EEA.

 

1. 1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data 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.

 

1. 1. Data retention
      1. How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for up to six years after they cease being clients for tax purposes.

 

1. 1. Your legal rights

You have the right to:

1. 1. • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
      • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
      • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
      • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
      • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
      • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
      • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

1. 1. 1. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

1. 1. 1. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

1. 1. 1. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

1. 1. Glossary
      1. Lawful basis

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.