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PRIVACY

POLICY

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Privacy Policy

We take data protection and your privacy very seriously at Vita Life Protect Ltd. Here’s how we
handle your information
Last updated: 18/03/2019
This privacy notice aims to give you information on how Vita Life Protect Ltd collects and
processes your personal data through your use of this website, including any data you may
provide when you submit our online contact form.
It is important that you read this privacy notice so that you are fully aware of how and why we are
using your data.

1. Who We Are

Data Controller:

Vita Life Protect Ltd, with registered company number 11853593 is the data controller and
responsible for your personal data (collectively referred to as “Vita Life Protect Ltd ”and/or
“vitalifeinsurance.co.uk)”, “we”, “us” or “our” in this privacy notice.
We are a registered data controller with the Information Commissioner’s Office, registration
number ZA505715

Contact Details:

Name: Vita Life Protect Ltd
Email address: admin@vitalifeinsurance.co.uk
Postal address: Vita Life Protect PO BOX 518, Manchester, M45 0GP

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 as follows:

  • Identity Data includes first name and last name.
  • Contact Data includes address, email address and telephone number(s).
  • Technical Data includes internet protocol (IP) address, 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.
  • Product Data includes form responses (the data entered and selected within our online contact
    form).
  • Usage Data includes information about how you use our website.
    We also collect, use and share Aggregated Data such as statistical or demographic data for any
    purpose. Aggregated Data may be derived from your personal data but is not considered
    personal data in law as this data does 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 notice.  
    We do not collect any Special Categories of Personal Data about you (this includes details about
    your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political
    opinions, trade union membership, information about your health and genetic and biometric
    data). Nor do we collect any information about criminal convictions and offences.

3. How We Collect Your Personal Data

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

  • Direct interactions. You may give us your Identity, Contact and Marketing and
    Communications Data by filling in forms or by corresponding with us by post, phone, email or
    otherwise.
  • Automated technologies or interactions. As you interact with our website, we may automatically
    collect Technical Data about your equipment, browsing actions and patterns. We collect this
    personal data by using cookies, pixels, server logs and other similar technologies. Please see
    our cookie policy for further details.
  • Technical Data from analytics providers such as Google
    4. 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:
  • Where we need to effectively perform the service you require
  • 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.
    Our lawful basis for processing your general personal data:

Legitimate interests: The processing necessary for the purposes
of the legitimate interests of the data controller or a third
party, except where such interests are overridden by the

Data used for the purpose of providing
the introduction to an FCA authorised
broker in order to provide the service

interests or fundamental rights or freedoms of the data subject

requested by the data subject

5. Sharing of Your Personal Data:

We may have to share your personal data with the parties set out below for the purposes set out
in our lawful basis for the processing of your general person data:

  • FCA authorised brokers by means of IT and system services which may be based on the data
    you have provided.
  • FCA authorised insurance brokers acting as data processors, joint data controllers or
    independent data controllers in order to provide the services required.

6. Your Legal Rights and Your Personal Data

Under certain circumstances, you have rights under data protection laws in relation to your
personal data. 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.
  • 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 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 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.  If you wish to exercise any of the rights set out above, please contact admin@vitalifeinsurance.co.uk for further details.

7. 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.

8. Data Retention

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.

9. Data Transfers to Third Countries

The data we collect from you may, on occasion, be stored and/or processed at a destination
outside the European Economic Area (EEA). It may also be processed by organisations
operating outside the EEA who work for us or for one of our suppliers. These organisations may
be engaged in the fulfilment of your request, order or reservation, and the provision of support
services.
Where we use certain service providers, we may use specific contracts approved by the
European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the
Privacy Shield which requires them to provide similar protection to personal data shared between
the Europe and the US.

We will take steps reasonably necessary to ensure there is an adequate level of protection of
your data and that your data is treated securely and in accordance with our Privacy Policy.

10. Cookies

We use cookies to distinguish you from other users of our Sites and Services. This helps us to
provide you with a good experience when you use our Sites and Services and also allows us to
improve them. 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.
We use the pieces of information that cookies record to help us improve services for you by, for
example:

  • enabling a service to recognise your device so you don’t have to give the same information
    several times during one task
  • recognising that you may already have given a username and password so you don’t need to do
    it for every web page requested
  • measuring how many people are using services, so they can be made easier to use and there’s
    enough capacity to ensure they are fast
  • analysing anonymised data to help us understand how people interact with govt services so we
    can make them better

How to control and delete cookies:

We will not use cookies to collect personally identifiable information about you.
However, if you wish to restrict or block the cookies which are set by our websites, or indeed any
other website, you can do this through your browser settings. The ‘Help’ function within your
browser should tell you how.
Alternatively, you may wish to visit the AboutCookies.org  website which contains comprehensive
information on how to do this on a wide variety of browsers. You will also find details on how to
delete cookies from your machine as well as more general information about cookies.
Please be aware that restricting cookies may impact on the functionality of our website.
If you wish to view your cookie code, just click on a cookie to open it. You’ll see a short string of
text and numbers. The numbers are your identification card, which can only be seen by the
server that gave you the cookie.
For information on how to do this on the browser of your mobile phone, please refer to your
handset’s user manual.

Cookies We Use and Why:
Strictly Necessary Cookies

These cookies let you move around the website and use essential features like secure areas.
These cookies don’t gather any information about you that could be used for marketing or
remembering where you’ve been on the internet.
We use these Strictly Necessary cookies to:

  • Remember things like information you’ve entered on forms
  • Make sure you connect to the right service on our website when we make any changes to the
    way the website works.
    Cookies we have defined as ‘Strictly Necessary’ cookies will not be used to:
  • Gather information that could be used to advertise products or services to you.
  • Remember your preferences or username beyond your current visit.
    Accepting these cookies is a condition of using the website, so if you prevent these cookies we
    can’t guarantee our website will perform as expected during your visit.

Performance Cookies

These cookies help identify information about how you use our website e.g. which pages you
visit, and if you experience any errors. These cookies don’t collect any information that could
identify you – all the information collected is anonymous and is only used to help us improve how
our website works, understand what interests our users, and measure how effective our
advertising is.
We use performance cookies to:

  • Provide statistics on how our website is used.
  • See how effective our adverts are (we don’t use these cookies to target adverts to you when you
    visit other websites).
  • Help us improve the website by measuring any errors that occur.
  • Test different designs of our website.
    Using our site indicates that you accept the use of ‘Performance’ cookies. Accepting these
    cookies is a condition of using the website, so if you prevent them we cannot guarantee how our
    site will perform for you.

Functionality cookies

Functionality cookies are used to provide services or to remember settings to improve your visit.
We use Functionality cookies to:

  • Remember settings you’ve applied such as layout, text size, preferences and colours.
  • Remember if we’ve already asked you if you want to fill in a survey or review.
  • Show you when you’re logged in to the website.
    Cookies defined as ‘Functionality’ will not be used to target you with adverts on other websites.

Preventing these cookies may mean we can’t offer you some services and will reduce the
support we can offer you. It’s also possible that preventing these cookies will stop us
remembering that you didn’t want a specific service.
For example, social media sharing cookies apply when you share our content on a social
network such as Facebook or Twitter.

Targeting/marketing cookies

We have relationships with carefully selected and trusted marketing suppliers. Sometimes you
might see our adverts on other websites. This is because a cookie has been used to deliver the
ad to you. It is important to understand that these cookies are completely anonymous – they are
only stored on your computer. No information is ever shared with other websites and you have
the ability to opt out of targeted marketing directly from these trusted suppliers.
Preventing these cookies may stop us from offering you some services. All of these cookies are
managed by third parties.

11. How to Make A Complaint

To exercise all relevant rights, queries or complaints, please contact us at admin@vitalifeinsurance.co.uk  to discuss your concerns.

Following this, if you are still dissatisfied, you are able to contact the Information Commissioner’s Office directly at https://ico.org.uk/  

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