Effective Date: 1 May 2025

1. Introduction

This Privacy Policy explains how we, [Your Company Name] trading as freeholderbuildinginsurance.co.uk (“we,” “us,” or “our”), collect, use, and protect your personal information when you visit our website or use our services.

We are an Introducer Appointed Representative and are committed to protecting your privacy and handling your personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Contact Information

Data Controller: Serpply Ltd
Portfleet Place
London
Email: [email protected]

3. Information We Collect

3.1 Information You Provide Directly

• Contact Information: Name, email address, phone number, postal address
• Insurance Inquiry Details: Property information, insurance requirements, current coverage details
• Communication Records: Records of your communications with us including emails, phone calls, and website inquiries

3.2 Information Collected Automatically

• Website Usage Data: IP address, browser type, pages visited, time spent on pages, referring websites
• Cookies and Similar Technologies: See our Cookie Policy section below
• Device Information: Device type, operating system, unique device identifiers

3.3 Information from Third Parties

• Insurance Partners: Information received from our authorized insurance partner when processing your inquiry
• Public Sources: Publicly available information relevant to insurance requirements

4. How We Use Your Information

We use your personal information for the following purposes:

4.1 Primary Purposes

• Service Provision: To introduce you to our authorized insurance partner and facilitate your insurance inquiries
• Communication: To respond to your inquiries and provide information about insurance services
• Referral Processing: To pass your details to our authorized insurance partner for quote provision

4.2 Secondary Purposes

• Website Improvement: To analyze website usage and improve our services
• Compliance: To meet legal and regulatory obligations
• Record Keeping: To maintain records of customer interactions for regulatory purposes

4.3 Legal Basis for Processing

• Legitimate Interests: For service provision and business operations
• Consent: Where you have provided explicit consent
• Legal Obligation: To comply with regulatory requirements

5. Information Sharing

5.1 Authorized Insurance Partner

We share your information with our authorized insurance partner who is regulated by the Financial Conduct Authority. This sharing is necessary to:

• Provide you with insurance quotes
• Process your insurance applications
• Deliver insurance services

5.2 Other Third Parties

We may share information with:

• Legal and Regulatory Authorities: When required by law or regulation
• Professional Advisors: Legal, financial, and other professional advisors
• Service Providers: Third-party service providers who assist in website operation (under strict confidentiality agreements)

5.3 We Do Not Sell Personal Data

We do not sell, rent, or lease your personal information to third parties for marketing purposes.

6. Data Retention

We retain your personal information for as long as necessary to:

• Fulfill the purposes outlined in this policy
• Comply with legal and regulatory obligations (typically 6 years for financial services records)
• Resolve disputes and enforce agreements

Specific retention periods:

• Inquiry Records: 6 years from last contact
• Website Analytics: 26 months
• Email Communications: 6 years

7. Your Rights

Under UK data protection law, you have the following rights:

7.1 Access Rights

• Right to Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate information
• Right to Erasure: Request deletion of your personal data (subject to legal obligations)

7.2 Control Rights

• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Request transfer of your data in a structured format
• Right to Object: Object to processing based on legitimate interests

7.3 Communication Rights

• Right to Withdraw Consent: Withdraw consent for processing where consent is the legal basis
• Right to Complain: Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise these rights, contact us using the details in Section 2.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption: Data transmitted to our website is encrypted using SSL technology
• Access Controls: Limited access to personal data on a need-to-know basis
• Regular Reviews: Periodic security assessments and updates
• Staff Training: Regular data protection training for all personnel

9. International Transfers

Your personal data is primarily processed within the UK. If we transfer data outside the UK, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the UK government
• Standard contractual clauses approved by UK authorities
• Other appropriate safeguards as required by law

10. Cookie Policy

10.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website.

10.2 Types of Cookies We Use

• Necessary Cookies: Essential for website functionality
• Analytics Cookies: Help us understand website usage (e.g., Google Analytics)
• Preference Cookies: Remember your choices and settings

10.3 Cookie Consent

We obtain your consent before placing non-essential cookies. You can manage cookie preferences through your browser settings.

10.4 Third-Party Cookies

Our website may include cookies from:

• Google Analytics (for website analytics)
• Other third-party service providers

11. Children’s Privacy

Our services are not directed at children under 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us immediately.

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable laws. We will:

• Post the updated policy on our website
• Notify you of significant changes via email or website notice
• Update the “Effective Date” at the top of this policy

13. Complaints

If you have concerns about how we handle your personal data, you can:

1. Contact Us Directly: Use the contact information in Section 2
2. Contact the ICO: Information Commissioner’s Office
   • Website: ico.org.uk
   • Phone: 0303 123 1113
   • Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

14. Additional Information

14.1 Financial Services Context

As an Introducer Appointed Representative, we operate under the oversight of our authorized insurance partner. Your data may be subject to additional regulatory requirements under Financial Conduct Authority rules.

14.2 Insurance Industry Requirements

The insurance industry has specific data retention and sharing requirements. We may need to retain your information longer than standard retention periods to comply with these obligations.

15. Contact Us

For any questions about this Privacy Policy or our data practices, please contact us: