Privacy Policy
George and Grey Insurance PCC Limited ("George and Grey", "we", "our" or "us") respects your privacy and is committed to the protection of your personal information.
This privacy policy tells you how we look after your personal data when you visit our website, regardless of where you visit it from, what your rights are in relation to your personal data and how the law protects you.
Purpose of this privacy policy
This privacy policy sets out the basis by which any personal information we collect from you, or that you provide to us (including through this website or when you purchase a product or service), will be processed by us in our capacity as controller, why we use such information, who we share it with and the rights to which you may be entitled. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Contact Details
Questions, comments and requests regarding this privacy policy or our privacy practices can be directed to the data privacy manager in the following ways:
Email: info@georgeandgrey.com
Postal Address: Data Privacy Manager, Cavello House Lamport Drive, Heartlands Business Park, Daventry, Northamptonshire, United Kingdom, NN11 8YH.
Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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 in the first instance please email info@georgeandgrey.com
Changes to this privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. If we change anything important about this policy (the information we collect, how we use it or why) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change. This version was last updated in May 2022.
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.
Changes to this privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. If we change anything important about this policy (the information we collect, how we use it or why) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change. This version was last updated in May 2022.
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.
Third Party Links
This 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 policy of every website you visit.
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 as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, gender any relevant registration details.
- 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 and other details of products and services you have purchased from us including your property details and any claims details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Vulnerability data - information about health, life events, resilience and capability that helps us identify if you might be a vulnerable person so that we can better meet your needs.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact Deatails by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- You register for, enquire about or enrol on any of our events or exhibitions;
- create an account on our website or manage your preferences through our website;
- subscribe to our newsletters or other publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our information on cookies for further details.
- Third parties or publicly available sources. We may on occasion receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the UK;
- advertising networks; and
- search information providers.
- Identity, Contact and Transaction Data from providers of building warranty and insurance providers
- Identity Data from third party providers of identity verification services for anti-fraud and anti-money laundering screening.
- Technical Data from the following parties:
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
We collect and use your personal information for a variety of reasons. However, rest assured 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:
- Where we need some information to enter into and perform our contract with you - for example your Transaction Data in connection with claims under our Buildmark products, Identity, Contact and Financial Data for builders and developers.
- Some information processing is required to comply with our legal obligations due to our anti-fraud and anti-money laundering screening obligations or in the public interest such as making sure we verify our customers' identities. We are also required to process certain data in order to comply with the legal requirements placed upon us by the Insurance Distribution Directive ((EU) 2016/97). Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency, to enforce or apply the terms of any contract or legal obligation with us or in the defence of a legal claim. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
- Other information we collect because we have legitimate business interests. Our legitimate business interests include:
- Registering you for, and communicating with you about, our events and exhibitions
- providing you with up-to-date technical information
- keeping you updated with regard to our fees and charges
- ensuring that our regulatory and legal obligations are complied with
- telling you about the various products and services that we provide
- making sure our records are up-to-date
- operating incentive programmes to encourage excellence
- making sure our products and services are paid for promptly and in full
- understanding how you use our products, services, training and materials
- obtaining and distributing feedback relating to quality of goods or services provided
- understanding and responding to your feedback
- providing communications relating to market and industry issues
- analysing the services our customers want
- improving our services
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sharing your personal information with third party organisations for their marketing purposes, where you give us your consent, this consent can be withdrawn at any time through the George and Grey Preference Centre which can be accessed via a link on our emails or manually by emailing info@georgeandgrey.com.
Purposes for which we will use your personal data
We use your personal information to conduct our business, to provide access to our on-line portals, to enable you to set up and operate an account with us, to enable you to access, use and/or purchase our services and products, to undertake surveys and for the purposes set out in more detail in this section.
We have set out below, in a table format, 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.
Please 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.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer | (a) Identity (b) Contact |
To process and deliver our products or services to you |
To process and deliver our products or services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) administer claims under any warranty or guarantee including through BuildMark |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review, take a survey or provide other feedback |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
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 inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
To administer our contract with you where you are a supplier or developer providing products or services to us (a) Manage payments, fees and charges (b) Ensure quality of service |
(a) Identity (b) Contract (c) Financial |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to ensure we are provided with a quality service and to administer our relationship with our service providers) |
To register you for our events and exhibitions and to communicate with you about the events and exhibitions which you have registered for | (a) Identity (b) Contact (c) Vulnerability (if provided) |
(a) Necessary for our legitimate interests (to enable us to run effective events and exhibitions); (b) Explicit Consent (only where you provide us with your Vulnerability data so that we can better meet your needs in relation to that exhibition or event). |
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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
We will only document any vulnerabilities you have declared where you consent to us doing so and then only so as to enable us to help better meet your needs and to comply with regulatory requirements about how we treat vulnerable people.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the George and Grey Preference Centre which can be accessed via a link on our emails or manually by emailing info@georgeandgrey.com.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, warranty claim or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see your rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We will take all reasonable care to keep your data secure and prevent unauthorised access to it. We have put in place appropriate security measures to prevent your personal data from being accidentally lose, used or accessed in an unauthorised way, altered or disclosed. All information you provide to us is stored on our secure servers. 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 process your personal data on our instructions and they are subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We may share your personal data with the parties set out below for the purposes set out in the table
Purposes for which we will use your personal data above.
- Other companies in the George and Grey Group and who are based in the UK so that we can provide the best service across the George and Grey Group in accordance with the legitimate interests of the George and Grey Group.
- We may also disclose your personal data to third parties in the following circumstances:
- if George and Grey or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
- if we seek to acquire other businesses or merge with them.
- if we are defending a legal claim your personal data may be transferred as required in connection with defending such claim
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligations, and other agreements; or to protect the rights, property, or safety of George and Grey, our customers or others.
- if necessary to our service providers acting as processors based in the UK who provide warranty support, [IT and system administration services].
- where required by our professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- if required by HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
- for the purposes of ensuring fraud prevention and meeting our legal obligations to fraud prevention agencies and anti-money laundering screening providers.
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.
Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.
International Transfers
We will only transfer data to jurisdictions outside the UK where there are appropriate safeguards in place to provide an adequate level of protection for your information.
Some of the external third parties referenced above may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We set out below the rights you have over your information and how you can exercise those rights.
Some of the rights listed below will only apply in certain circumstances as explained below
You have the right to:
- 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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.
- Make a complaint. You have the right to complain to the relevant supervisory authority which in the United Kingdom is the Information Commissioner's Office (www.ico.org.uk).
To exercise your rights you can email your request to our data privacy manager at info@georgeandgrey.com.
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 could refuse to comply with your request in these circumstances.
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, and to provide information to help us improve the website user experience and deliver a better service. Some of the cookies we use are essential for the site to operate.
A cookie will typically contain a record of the website which issued it, its own name, and a value which is often a randomly generated unique number. A cookie will have a 'lifetime', which tells your browser when to delete it.
What do we use cookies for?
Different cookies are used for different purposes. The most common ones are as follows:
Necessary cookies (also known as 'essential cookies') help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. Without these cookies, the website may not be able to provide many services that the users expect from it.
Preference cookies (also known as 'functionality cookies') enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
Statistic cookies (also known as 'analytic' or 'performance cookies') these cookies collect information about how you use a website, like which pages you visited, and which links you clicked on. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. None of this information can be used to identify you. It is all aggregated and, therefore, anonymised.
Advertising & marketing cookies (also known as 'targeting cookies') are used for advertising and marketing purposes and track visitors across websites. These cookies are used to identify your interests and display ads that are relevant and engaging to you by understanding how you interact with our websites and third-party advertisers. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organisations or advertisers. These are persistent cookies (as to which see below) and almost always of third-party provenance.
There are also several different types of cookie. These are the most common ones:
Session cookies. Session cookies only last for the duration of your website visit. A web browser normally deletes session cookies when it quits.
Persistent cookies. Persistent cookies will outlast user sessions. If a persistent cookie has its maximum age set to 1 year, then, within the year, the initial value set in that cookie would be sent back to the server every time the user visited the server. This could be used to record a piece of information such as how the user initially came to this website. For this reason persistent cookies are also called tracking cookies.
Secure cookies. Secure cookies are only used when a browser is visiting a server via HTTPS, ensuring that the cookie is always encrypted when transmitting from client to server.
First-party cookies. First-party cookies are cookies set with the same domain (or its subdomain) in the browser's address bar.
Third-party cookies. Third-party cookies are cookies set with different domains from the one shown on the address bar (i.e. the web pages on that domain may feature content from a third-party domain - e.g. Google Maps or YouTube). Privacy setting options in most modern web browsers allow you to block third-party tracking cookies.
The cookies we use
The table below provides an overview of the cookies used on our website, including details of who sets each cookie, its purpose, when it expires, and, if relevant, how you can find out further information.
Name | 1st or 3rd party(if 3rd party, who?) | What is the purpose of the cookie | Lifetime | Further information |
---|---|---|---|---|
The cookie [is essential for our site to][enable us to][(a) Estimate our audience size and usage pattern.] [(b) Store information about your preferences, and so allow us to customise our site and to provide you with offers that are targeted at your individual interests.] |
[WHERE APPROPRIATE, INSERT LINK TO EXTERNAL INFORMATION] |
Managing your cookie preferences
We don't give you the option to turn off essential cookies when you manage your cookie preferences because these cookies are necessary to make our sites function properly. For the other categories of cookies, you can control how they are used on George and Grey site.
Other ways to manage your cookie preferences
You have the ability to accept or decline cookies. Most internet browser software automatically accepts cookies, but you can usually modify your browser software setting to decline cookies, or receive a warning before a cookie is stored, if you prefer. Please refer to your internet browser's instructions or help screen to learn more about these functions.
You can disable or remove cookies from your computer by using your browser settings. However, if you use your browser settings to block all cookies (including strictly necessary or essential cookies) you may not be able to access all or parts of our site.
Remember, deleting your cookies or accessing our website from a different browser or device will effectively ignore your existing preferences for using our website. In a few cases, blocking cookies may reduce the functionality of some websites or prevent access to them altogether.
For further information about cookies, visit www.allaboutcookies.org.
To find information relating to other browsers, visit the browser developer's website.
To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.