How we use your personal information
What personal information we use when you buy one of our products
Where you take out life insurance with us, we’ll collect and use your personal information to arrange, underwrite and manage your policy, as well as prevent fraud and handle claims. We’ll also collect the family or personal history of the insured person, or details of appointed trustees where policies are placed under trust.
If you buy a product directly from our website or other Samie Capital’s sales channel, we’ll ask for payment information. We need this to complete your purchase.
If a claim is made, we use the personal information to verify the identity of the policyholder and (if different) provide details of the insured, so that we can identify them. We’ll also need you to provide details of the claim so that we can assess the claim. Where necessary, this will include providing details of any accidents or personal injuries that have been suffered as part of the claim, either by an insured person or third party. In certain circumstances, it may be necessary to collect details of alleged offences in relation to an insured person.
We’ll also use your personal information to detect and prevent fraudulent practices, fight financial crime and meet our regulatory responsibilities. If you’re making a claim, we may use profiling and other forms of automated processing to assess if your claim may be fraudulent. This assessment may involve the use of your sensitive personal information.
How we collect, use and share personal information
Respecting privacy rights:
We’re committed to collecting and using personal information in accordance with applicable data protection laws.
Wherever we collect or use this information, we’ll make sure we do this for a valid legal reason. This will be for at least one of the following purposes:
- to arrange, underwrite or manage our products, or handle claims in accordance with their terms
- to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities
- to operate and improve our products and services and keep people informed about our products and services or for any other purposes we identify as relevant to further our business interests but never at the expense of your privacy rights (we refer to these activities as our legitimate interests)
- where we have obtained appropriate consents to collect or use your personal information for a particular purpose
Marketing and marketing preferences:
We may use personal information to send direct marketing communications about our products and services that we feel you’ll be interested in. This may be in the form of email, post, SMS, telephone or display advertising you may see on websites, social media, television or search results.
To protect your privacy rights and give customers choice and control over the use of their personal information, you can:
always ‘opt out’ of receiving direct marketing when registering with us, requesting an online quote, purchasing a product or service online at any time. All our marketing communications include unsubscribe links to help you manage your marketing preferences.
- change your marketing preferences in your client portal (if you’re registered) or by contacting us if you change your mind. Opting out of one type of marketing, for example, by email or telephone, doesn’t mean you’re opted out of all marketing. Bear this in mind when you manage your preferences. You can always contact us directly if you would like us to stop all forms of direct marketing. We try to limit direct marketing and only send you offers and promotions that you might be interested in, based on information we have about you. We won’t send you spam.
We rely on third-party advertising technology (such as the deployment of cookies or small text files on our website) to collect information about you, which is used to optimise what you may see on our websites and deliver content when you are browsing elsewhere. We may also collect information about your use of other websites. We do this to provide you with advertising that we believe may be relevant for you, as well as to improve our own products and services.
- Our online advertising complies with the best practice recommendation set by the European Advertising Alliance and you will always see the Samie Capital logo on display ads visible on third-party sites.
- If we use or share information with online sources, such as websites, social media and information sharing platforms, we will respect any permissions you have set about how you would like your personal information to be used.
- We recommend you routinely review the privacy notices and preference settings that are available to you in client portal and on social media platforms you use as they will dictate how adverts and other messages are displayed and shared across those platforms.
- If you choose to opt out of tailored offers and advertising, you’ll still continue to see generic advertising displayed online, it just might not be as relevant to you.
Using personal information to improve our products and services
We use digital tools when you visit our websites or use our mobile apps to gain insights into our products, services and the functionality and performance of our websites, apps and platforms. For example, we use some of these tools to save your language preferences on our website, so we’re able to offer you our services in the language you prefer.
Working with Credit Reference Agencies (CRA):
For certain products, to ensure we have the necessary facts to assess your insurance risk, verify your identity, help prevent fraud and provide you with our best premium and payment options, we may obtain information relating to you at quotation, renewal and, in certain circumstances, where policy amendments are requested. This may include a quotation search that will appear on your credit report and be visible to other credit providers. Where you agree to pay monthly under an Samie Capital’s agreement, the status of your quotation search from our CRA will be updated to reflect your credit application and this will be visible to other credit providers. CRAs may keep a record of this search.
To assess your application we’ll supply your personal information to our CRAs and they’ll give us information about you, such as your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We’ll also continue to exchange the information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates..
Working with regulators and fraud prevention and detection agencies:
We may use your personal information to help us to detect and prevent fraudulent applications and claims, fight financial crime and meet our regulatory responsibilities. This may involve checking public registers (eg the electoral roll or registers of county court judgments, bankruptcy orders or repossessions), conducting online searches from websites, social media and other information sharing platforms and using databases managed by credit reference agencies and other reputable organisations. This will help us verify your identity, make decisions about providing you with our products and related services, and trace debtors or beneficiaries. We may also share your information and undertake searches with third party organisations such as police, public bodies, credit reference agencies, fraud prevention agencies and our regulators. If you give us false or inaccurate information and we suspect fraud, we’ll record this to prevent further fraud and money laundering.
We can supply on request further details of the agencies and databases we access or contribute to and how this information may be used. If you require further details contact us at 204 577 0291, or email firstname.lastname@example.org Reference: Financial Crime
Working with Reinsurers:
We may share (either directly or through brokers) your personal information, including sensitive personal information, with reinsurers who provide reinsurance services to Samie Capital and for each other in respect of risks underwritten by Samie Capital and with insurers who cover Samie Capital and under its group insurances policies.
They will use your data to decide whether to provide reinsurance and insurance cover, assess and deal with reinsurance and insurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
We can supply on request further details of the reinsurers and insurers we provide your data to and how this information may be used. If you require further details contact us using the details at the bottom of the page.
Using personal information to create profiles and create better products:
Where we underwrite products, we use an automated underwriting engine to process the personal information you provide as part of your application process, together with information provided by third party sources (this could include sensitive information such as health information and offences and convictions) along with the amount of cover you wish to obtain.
Without this information we’re unable to provide a price that is relevant to your individual circumstances and needs.
We regularly check the way our underwriting engine works and before using data obtained from third parties we rigorously test it to identify whether the data provides any actionable insight. This is done using the bare minimum amount of hashed or obscured data we hold about our customers. We do this in order to continually improve the quality of our services, the efficacy of our algorithms and to help us to continue to be fair to our customers.
If you are making a claim, we may use profiling or other forms of automated processing to assess the probability that your claim may be fraudulent or suspect in some way.
Retaining personal information in our systems:
To support us in managing how long we hold your data and our record management, we maintain a data retention policy which includes clear guidelines on data deletion.
We may also retain personal information where we have identified a legal basis for doing so in an aggregated form which allows us to continue to develop/improve our products and services.
Protecting information outside the UK:
Some of the organisations we share information with may be located outside of the European Economic Area (“EEA”). We’ll always take steps to ensure that any transfer of information outside the EEA is carefully managed to protect your privacy rights:
- transfers within Samie Capital will be covered by an agreement entered into by members of Samie Capital (an intra-group agreement) which contractually obliges each member to ensure that your personal information receives an adequate and consistent level of protection wherever it is transferred within the Group;]
- where we transfer your data to non- Samie Capital members or other companies providing us with a service, we’ll obtain contractual commitments and assurances from them to protect your personal information. Some of these assurances are well recognised certification schemes such as standard contractual clauses and the EU – U.S. Privacy Shield for the protection of personal information transferred from within the EU to the United States of America
- we’ll only transfer personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights; and
- any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed
You have a right to ask us for more information about the safeguards we have put in place as mentioned above.
You have legal rights under data protection laws in relation to your personal information. Read below to learn more about each right you may have.
We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information where we know we’re dealing with the right individual.
We’ll not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we’ll inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We’ll always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.
We may not always be able to do what you have asked, for example if it would impact the duty of confidentiality we owe to others, or if we’re otherwise legally entitled to deal with the request in a different way.
Accessing personal information:
You can ask us to:
- confirm whether or not we have and are using your personal information
- get a copy of your personal information
Where we’ve asked for your consent to use your personal information, you’ll always have the right to withdraw such consent. Please contact us if you want to do this. If you withdraw your consent, we may not be able to provide certain products and services to you. If this is the case, we’ll tell you at the time you ask to withdraw your consent.
Correcting / erasing personal information:
You can ask us to:
- correct any information about you which is incorrect. We’ll be happy to correct such information but will need to verify the accuracy of it first
- erase your personal information if you think we no longer need to use it for the purpose we collected it from you
- erase your personal information if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, where we have used it unlawfully or where we’re subject to a legal obligation to erase your personal information
We may not always be able to comply with your request, for example, if we need to keep using your personal information in order to comply with our legal obligation or where we need to use it to establish, exercise or defend legal claims.
Restricting our use of personal information:
You can ask us to restrict our use of your personal information in certain circumstances, for example, where:
- you think the information is inaccurate and we need to verify it
- our use of your personal information is not lawful but you do not want us to erase it
- the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
- you have objected to our use of your personal information but we still need to verify if we have overriding grounds to use it
We can continue to use your personal information following a request for restriction if we have your consent to use it; or you need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.
Objecting to use of personal information:
You can object to any use of your personal information which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal information if we can demonstrate that we have compelling legitimate interests to use the information.
Requesting a transfer of personal information:
You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (eg another company).
You may only exercise this right where we use your personal information in order to perform a contract with you, or where we asked for your consent to use your personal information. This right does not apply to any personal information which we hold or process based on our legitimate interest or which is not held in digital form.
Contesting decisions based on automated decision making:
If we made a decision about you based solely by automated means (ie with no human intervention), and our decision produces a legal effect concerning you (such as the rejection of your claim), or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we’re authorised by law to make such decisions and have adopted suitable safeguards in our decision-making processes to protect your rights and freedoms.
Obtaining a copy of our safety measures:
You can ask for a copy of, or reference to, the safeguards we have put in place when your personal information is transferred outside of the European Economic Area. We’re not required to share details of these safeguards if sharing such details would affect our commercial position, or create a security risk.
Obtaining a copy of our safety measures:
- what personal information we have about you
- what we use it for
- who we share it with
- whether we transfer it abroad
- how we protect it
- how long we keep it for
- what rights you have
- how you can make a complaint
- where we got your data from
- whether we have carried out any automated decision making using your personal information.
Write to: The Data Protection Team, Samie Capital, 321-323 High Road Chadwell Heath, Romford, London, United Kingdom, RM6 6AX
Email us: email@example.com Reference: DATA PR
Your right to complain
If you’re not happy with the way we’re handling your information, you have a right to make a complaint with your local data protection supervisory authority at any time. In the UK this is the Information Commissioners Office (ICO).
We ask that you please attempt to resolve any issues with us before contacting the ICO.