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Privacy Policy


PRIVACY POLICY




ABOUT THIS NOTICE

Axco Insurance Information Services Limited, part of Wilmington plc, is
committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about
you in accordance with data protection law. Please read it carefully.

Data protection law says that the personal information we hold about you must
be:

 * Used lawfully, fairly and in a transparent way.
 * Collected only for valid purposes that we have clearly explained to you and
   not used in any way that is incompatible with those purposes.
 * Relevant to the purposes we have told you about and limited only to those
   purposes.
 * Accurate and kept up to date.
 * Kept only as long as necessary for the purposes we have told you about.
 * Kept securely.

This notice is separated into the following sections for ease of reference. If
you have any questions about this notice or how we collect and use personal
information about you please contact us at axco@axcoinfo.com.

 


1. INFORMATION ABOUT US

1.1 We are Axco Insurance Information Services Limited Our registered office is
at 5th Floor, Whitechapel Building, 10 Whitechapel High Street, London E1 8QS
and our registered company number is GB 899 3725 51.

1.2 If you have any questions, our contact details are:

5th Floor, Whitechapel Building, 10 Whitechapel High Street, London E1 8QS

+44 20 7374 5252

axco@axcoinfo.com

1.3 We also have a dedicated Data Protection Officer, who is responsible for
data compliance issues. Their contact details are below:

+44 20 7324 2346

dataprotection@wilmingtonplc.com

 


2. CONTRACT INFORMATION AND OTHER CORRESPONDENCE

2.1 When you enter into a contract with us (or someone does so on your behalf)
there will be personal information about you relating to that contract such as
your name, contact details, contract details, delivery details, and
correspondence with us about the contract.

2.2 We need certain information to carry out our contract with you and you must
provide this in order to enter into a contract with us (or as required under
that contract), if you do not, we may not be able to carry out our contract with
you. Mandatory information fields are generally set out when you are entering
into the contract, but in particular, you must provide the following
information:

 * Your name and contact details.
 * Your address.
 * Your payment details.
 * Information to verify your identity and other information for us to carry out
   anti money laundering checks.
 * Name and contact details of individual consumers of our products covered by
   the contract and authorised to use our services.

2.3 Other correspondence or interaction (for example by email, telephone, post,
SMS or via our website) between you and us, will include personal information
(such as names and contact details) in that correspondence. This may include
enquiries, reviews, follow-up comments or complaints lodged by or against you
and disputes with you or your organisation.

2.4 Call information. We may also collect details of phone numbers used to call
our organisation and the date, time and duration of any calls. Please note that
we may record your calls to or from us for quality and training purposes.

2.5 We will keep and use that information to carry out our contract with you (if
applicable), to comply with any legal requirements for us to maintain certain
records or carry out certain verifications, and/or for our legitimate interests
in dealing with a complaint or enquiry and administering your (or your
organisation’s) account or order and any services we offer, as well as to review
and improve our offerings, including troubleshooting, data analysis, testing,
research, statistical and survey purposes.


3. MARKETING

3.1 We may collect your name and contact details (such as your email address,
phone number or address) in order to send you information about our products and
services which you might be interested in. We may collect this directly from
you, or through a third party. If a third party collected your name and contact
details, we will process your professional data based on legitimate interests to
send you a fair processing notice and then respect any communication preferences
you give us.

3.2 You always have the right to “opt out” of receiving our marketing. You can
exercise the right at any time by contacting us at axco@axcoinfo.com. If we send
you any marketing emails, we will always provide an unsubscribe option to allow
you to opt out of any further marketing emails. If you “opt-out” of our
marketing materials you will be added to our suppression list to ensure we do
not accidentally send you further marketing. We may still need to contact you
for administrative or operational purposes, but we will make sure that those
communications don’t include direct marketing.

3.3 If you are an existing customer or are acting as a business we use your
contact details as necessary for our legitimate interests in marketing to you
and maintaining a list of potential customers.

3.4 We never share your name or contact details with third parties for marketing
purposes. We do use third party service providers to send out our email
marketing, but we only allow them to use that information on our instructions
and where they have agreed to treat the information confidentially and to keep
it secure.

3.5 We retain your details on our marketing list until you “opt-out” at which
point we add you to our suppression list. We keep that suppression list
indefinitely to comply with our legal obligations to ensure we don’t
accidentally send you any more marketing.


4. WEBSITE INFORMATION

4.1 We may collect information about you and your use of our websites via
technical means such as cookies, webpage counters and other analytics tools. We
use this as necessary for our legitimate interests in administering our website
and to ensure it operates effectively and securely.

4.2 For detailed information on the cookies we use and the purposes for which we
use them see our Cookie Notice.

4.3 We keep this website information about you from when it is collected until
the relevant cookie expires or you disable it.

4.4 Our website may, from time to time, contain 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.


5. CONTENT ACCESS

5.1 This is your account login information for the Axco online portal.

5.2 This information is kept for as long as you have an account with us and may
be retained for 36 months after cancellation of services for the purposes of
usage statistics.


6. INFORMATION COLLECTED AT OUR PREMISES

6.1 Visitor information. We collect information about visitors to our Head
office. We may record information on your visit, including the date and time,
who you are visiting, your name, employer, contact details and vehicle
registration number. If you have an accident at our premises, this may include
an account of your accident.

6.2 CCTV. We, or our building management company, may operate CCTV at our
premises which may record you and your activities. We display notices to make it
clear what areas are subject to surveillance. We only release footage following
a warrant or formal request from law enforcement, or as necessary in relation to
disputes.

6.3 We use this information as necessary for our legitimate interests in
administering your visit, ensuring site security and visitor safety, and
administering parking.

6.4 Visitor information is kept for a period of up to 3 months. If you have an
accident on our premises, our accident records are retained for a period of up
to 3 years.

6.5 CCTV recordings may be kept for a period of up to 35 days (unless there an
incident occurs and it is necessary for us to keep recordings for longer to
properly deal with it).


7. JOB APPLICANTS

7.1 We will collect and hold information on job applicants, including
information you provide to us in your application, or provided to us by
recruitment agencies, as well as information on you from any referees you
provide.

7.2 We use this as necessary to enter into an employment contract with you, and
for our legitimate interests in evaluating candidates and recording our
recruitment activities, and as necessary to exercise and perform our employment
law obligations and rights.

7.3 If you are successful in your application, your information will be used and
kept in accordance with our internal privacy notice. If you currently work for
us, or used to work for us, you can request a copy of this from us. If you are
not successful in your application, you information will be held for up to 6
months after the relevant round of recruitment has finished.

7.4 You must provide certain information (such as your name, contact details,
professional and educational history) for us to consider your application fully.
If you have not provided all of this information, we may contact you to ask for
it. If you do not wish to provide this information, we may not be able to
properly consider your application.

7.5 If you are listed as a referee by an applicant, we will hold your name,
contact details, professional information about you (such as your employer and
job title) and details of your relationship with the applicant. We will use this
information as necessary for our legitimate interests in evaluating candidates
and as necessary to exercise and perform our employment law obligations and
rights. Your information will be kept alongside the applicant’s information.

7.6 If you are listed as an emergency contact by someone who works for us, we
will hold your name, contact details and details of your relationship with that
worker. We will use this to contact you as necessary to carry out our
obligations under employment law, to protect the vital interests of that worker,
and for our legitimate interests in administering our relationship with that
worker. Your information will be kept until it is updated by that worker, or we
no longer need to contact that worker after they have stopped working for us.


8. LEGAL CLAIMS

8.1 Where we consider there to be a risk that we may need to defend or bring
legal claims, we may retain your personal information as necessary for our
legitimate interests in ensuring that we can properly bring or defend legal
claims. We may also need to share this information with our insurers or legal
advisers. How long we keep this information for will depend on the nature of the
claim and how long we consider there to be a risk that we will need to defend or
bring a claim.


9. INFORMATION WE RECEIVE FROM THIRD PARTIES

9.1 We may also receive information about you from the following sources:

 

    9.1.1 Our service providers. We work closely with third parties (including,
for example, business partners, sub-contractors in technical, payment and
delivery services, advertising networks, analytics providers, search information
providers and credit reference agencies) who may provide us with information
about you, to be used as set out above.

 

    9.1.2 Businesses we have bought. If we have acquired another business, or
substantially all of its assets, which originally held your information, we will
hold and use the information you provided to them, or which they otherwise held
about you, in accordance with this privacy notice.

 

    9.1.3 Our other channels. This is information we receive about you if you
use any of the other websites we operate or the other services or products we
provide. In this case we will have informed you when we collected that data if
we intend to share those data internally and combine it with data collected on
this website. We will also have told you for what purpose we will share and
combine your data.

 

    9.1.4 Publicly available sources. We obtain information from the following
publicly available sources: your employer website, Companies House or LinkedIn

 

    9.1.5 Credit information. We may also collect credit information on you from
third party reference agencies.


10. WHY ELSE DO WE USE YOUR INFORMATION?

10.1 Common uses of your information. We will only use your personal information
when the law allows us to do so. Although in limited circumstances we may use
your information because you have specifically consented to it, we generally use
your information in the ways set out in this notice because:

    10.1.1 we need to perform a contract we have entered into with you.

    10.1.2 we need to comply with a legal obligation.

    10.1.3 it is necessary for our legitimate interests (or those of a third
party) and your interests and rights do not override those interests.

    10.1.4 we need to protect your interests (or someone else’s interests) or
where it is needed in the public interest (although these circumstances are
likely to be rare).

10.2 Change of purpose. We will only use your personal information for the
purposes for which we collected it as set out in this notice, 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
information for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.


11. SHARING YOUR INFORMATION

As well as any sharing listed above, we may also share your information with
third parties, including third-party service providers and other entities in our
group. Third parties are required to respect the security of your personal
information and to treat it in accordance with the law. We never sell your data
to third parties.

11.1 CCPA Notice

We never sell your data to third parties.

11.2 Why might we share your personal information with third parties?

We may share your personal information with third parties if we are under a duty
to disclose or share your personal information in order to comply with any legal
obligation, or in order to enforce or apply our agreements with you, or to
protect the rights, property, or safety of us, our customers, or others or where
we have another legitimate interest in doing so. This may include exchanging
information with other companies and organisations for the purposes of fraud
protection and credit risk reduction.

11.3 Which third-party service providers process your personal information?

We also may need to share your personal information with third-party service
providers (including contractors and designated agents) so that they can carry
out their services.

The following activities are carried out by third-party service providers: CRM
system, digital marketing service providers, feedback and review platforms, IT
development, IT services, legal advice, payment processing systems, editorial
contributor and webinar platforms.

11.4 When might we share your personal information with other entities in the
group?

We may share your personal information with other entities in our group in our
shared CRM, data analytics, email marketing and finance systems as part of our
regular provision of services, reporting activities on company performance, for
the management of events, in the context of a business reorganisation or group
restructuring exercise, and for system maintenance support and hosting of data.

11.5 How secure is your information with third-party service providers and other
entities in our group?

All our third-party service providers and other entities in the group are
required to take appropriate security measures to protect your personal
information. Where third parties process your personal information on our behalf
as “data processors” they must do so only on our instructions and where they
have agreed to treat the information confidentially and to keep it secure.

11.6 What about other third parties?

We may share your personal information with other third parties, for example in
the context of the possible sale or restructuring of the business where
necessary in connection with the purposes which your information was collected
for. We may also need to share your personal information with a regulator or to
otherwise comply with the law.


12. WHERE WE STORE YOUR INFORMATION

12.1 Our office headquarters are based in London and our main data centre is
located in Telford, UK. However, where required to perform our contract with you
or for our wider business purposes, the information that we hold about you may
be transferred to, and stored at, a destination outside the UK and the EU. It
may also be processed by staff operating outside the UK and EU who work for us
or for one of our service providers. In particular, we operate in the following
countries: Dubai, India, Malaysia and USA.

 

12.2 We will take all steps reasonably necessary to ensure that your personal
information is treated securely and in accordance with this privacy notice.

 

Some countries or organisations outside of the UK and the EU which we may
transfer your information to will have an “adequacy decision” in place, meaning
the EU considers them to have an adequate data protection regime in place. These
are set out on the European Commission website:
https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

 

12.3 If we transfer data to countries or organisations outside of the UK and the
EU which the EU does not consider to have an adequate data protection regime in
place, we will ensure that appropriate safeguards (for example, model clauses
approved by the EU or a data protection authority) are put in place where
required. To obtain more details of these safeguards, please contact us.


13. DATA SECURITY

13.1 As well as the measures set out above in relation to sharing of your
information, we have put in place appropriate internal security measures to
prevent your personal information from being accidentally lost, used or accessed
in an unauthorised way, altered or disclosed. In addition, we limit access to
your personal information to those employees, agents, contractors and other
third parties who have a business need to know. They will only process your
personal information on our instructions and they are subject to a duty of
confidentiality.

13.2 We have put in place procedures to deal with any suspected data security
breach and will notify you and any applicable regulator of a suspected breach
where necessary.


14. HOW LONG WILL WE KEEP YOUR INFORMATION FOR?

14.1 We have set out above indications of how long we generally keep your
information. In some circumstances, it may be necessary to keep your information
for longer than that in order to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting
requirements.

 

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

 

14.3 In some circumstances we may anonymise your personal information so that it
can no longer be associated with you, in which case we may use such information
without further notice to you.


15. YOUR RIGHTS

15.1 Data protection law gives you a number of rights when it comes to personal
information we hold about you. The key rights are set out below. More
information about your rights can be obtained from the Information
Commissioner’s Office (ICO). Under certain circumstances, by law you have the
right to:

    15.1.1 Be informed in a clear, transparent and easily understandable way
about how we use your personal information and about your rights. This is why we
are providing you with the information in this notice. Please let us know if you
require any further information about how we use your personal information.

    15.1.2 Request access to your personal information (commonly known as a
“data subject access request”). This enables you to receive a copy of the
personal information we hold about you and to check that we are lawfully
processing it.

    15.1.3 Request correction of the personal information that we hold about
you. This enables you to have any incomplete or inaccurate information we hold
about you corrected.

 

    15.1.4 Request erasure of your personal information. This enables you to ask
us to delete or remove personal information where there is no good reason for us
continuing to process it (for instance, we may need to continue using your
personal data to comply with our legal obligations). You also have the right to
ask us to delete or remove your personal information where you have exercised
your right to object to processing (see below).

 

    15.1.5 Object to processing of your personal information 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 us
using your information on this basis and we do not have a compelling legitimate
basis for doing so which overrides your rights, interests and freedoms (for
instance, we may need it to defend a legal claim). You also have the right to
object where we are processing your personal information for direct marketing
purposes.

 

    15.1.6 Request the restriction of processing of your personal information.
This enables you to ask us to suspend the processing of personal information
about you, for example if you want us to establish its accuracy or the reason
for processing it.

 

    15.1.7 Request the transfer of your personal information to another party
where you provided it to us and we are using it based on your consent, or to
carry out a contract with you, and we process it using automated means.

 

    15.1.8 Withdraw consent. In the limited circumstances where we are relying
on your consent (as opposed to the other bases set out above) to the collection,
processing and transfer of your personal information for a specific purpose, you
have the right to withdraw your consent for that specific processing at any
time. Once we have received notification that you have withdrawn your consent,
we will no longer process your information for the purpose or purposes you
originally agreed to, unless we have another legitimate interest in doing so.

 

    15.1.9 Lodge a complaint. If you think that we are using your information in
a way which breaches data protection law, you have the right to lodge a
complaint with your national data protection supervisory authority (if you are
in the UK, this will be the ICO).

 

If you want to review, verify, correct or request erasure of your personal
information, object to the processing of your personal information, withdraw
your consent to the processing of your personal information or request that we
transfer a copy of your personal information to another party, please contact us
at axco@axcoinfo.com.

 

15.2 No fee usually required. You will not have to pay a fee to access your
personal information (or to exercise any of the other rights). However, we may
charge a reasonable fee if your request for access is clearly unfounded or
excessive. Alternatively, we may refuse to comply with the request in such
circumstances.

 

15.3 What we may need from you. We may need to request specific information from
you to help us understand the nature of your request, to confirm your identity
and ensure your right to access the information (or to exercise any of your
other rights). This is another appropriate security measure to ensure that
personal information is not disclosed to any person who has no right to receive
it.

 

15.4 Timescale. Please consider your request responsibly before submitting it.
We will respond to your request as soon as we can. Generally, this will be
within one month from when we receive your request but, if the request is going
to take longer to deal with, we will let you know.


16. CHANGES TO THIS PRIVACY NOTICE

Any changes we make to our privacy notice in the future will be posted on this
page and, where appropriate, notified to you by e-mail or otherwise. Please
check back frequently to see any updates or changes to our privacy notice.




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© 2023 – Axco Insurance Information Services, a division of Wilmington plc. Axco
Insurance Information Services Limited is a company registered in England &
Wales with company number 03073807 GB. Registered office: Fifth Floor, 10
Whitechapel High Street, London, E1 8QS. VAT Number: GB 899 3725 51.


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