Privacy Statement

Cornmarket: Privacy and Security

Here at Cornmarket Insurance Services (Cornmarket) we care about your privacy and we respect your privacy rights. Cornmarket is registered with the Information Commissioners Office and is required to comply with the Data Protection Law. We only use any personal information which you provide on the website for the intended purposes of your application for any services offered by Cornmarket together with the facilitation of those services. We will at all times keep your personal data safe and secure.

By using the Cornmarket website, you permit the collection and use of your personal information as outlined below and you signify your agreement to this Website Privacy Statement (last updated May 2018). If you do not agree with these terms, you should not use the Cornmarket website.

1. About Our Website Privacy Statement

1.1 Our website www.cornmarketinsurance.co.uk, including all the webpages containing that address, (the “Cornmarket website”) is operated by Cornmarket Insurance Services Ltd. of Boucher Plaza, 4- 6 Boucher Road, Belfast BT12 6HR, Cornmarket Insurance Services Ltd is registered in Northern Ireland: N.I.030039.

1.2 Cornmarket Insurance Services Ltd is authorised by the Financial Conduct Authority in the UK. Our Firm’s Reference Number is 308099 and details of our registration with the FCA can be found at http://www.fca.org.uk or by contacting them on 0800 111 6768.

1.3 Our agreement with you (together with our terms and conditions, any Cornmarket product terms and conditions and any other documents referred to in these documents) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, including the data collected in relation to contracts of insurance with insurers for which we act as an insurance brokers, which we allow the Cornmarket website users to request, contract for, manage, claim in respect of and otherwise deal with via the Cornmarket website from time to time at our sole discretion (each a “Cornmarket Product”).

1.4 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1.5 You understand that this Website Privacy Statement deals with your relationship with Cornmarket. When contracting with an insurer for a Cornmarket product using the Cornmarket website you understand that you enter into a separate agreement with the insurer and that you should review the terms and conditions of the relevant Cornmarket product to determine what use the insurer may make of your data, or what additional terms and conditions apply to that insurer’s use, that is additional to the use that is envisaged by this Website Privacy Statement.

2. How We Collect Information On The Cornmarket Website

2.1 When contracting for a Cornmarket product on the Cornmarket website you will be asked to provide information to us. We will inform you at the time of collecting information from you whether you must provide the information to enter into a contract for a Cornmarket product or whether the provision of information requested by us is optional.

2.2 We may collect and process the following data about you when you use the Cornmarket website:

2.2.1 If you contact us, we may keep a record of that correspondence.

2.2.2 Information that you submit when you apply for a Cornmarket product, which may include but is not limited to your name, email address, payment details, renewal date(s) and date of birth.

2.2.3 Where you are applying or using our website to deal with a Cornmarket product in connection with a union membership, details of your union membership and your profession. We will seek consent from you in order to process your trade union membership.

2.2.4 Where you are applying or using our website to deal with a Cornmarket product in connection with life assurance or health insurance, details concerning your health, age and whether you are a member of a trade union. Other sensitive data may be collected in the event of a claim, details of which will be provided at that time.

2.2.5 Other information that you submit when you use the Cornmarket website.

2.2.6 Details of transactions you carry out through the Cornmarket website; and

2.2.7 Details of your visits to the Cornmarket website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

3. Uses Made Of The Information

3.1 We use information held about you in the following ways:

3.1.1 To ensure that content from Cornmarket is presented in the most effective manner for you and for your computer.

3.1.2 To provide you with information, products or services that you request from us.

3.1.3 To quote or process your purchase of a Cornmarket product on behalf of an insurer.

3.1.4 To process your request for a quote, or your offer to enter into a contract for a Cornmarket product, on your behalf, and to submit your data to an insurer or insurers on your behalf for this purpose.

3.1.5 To process your claim for a payment in connection with a Cornmarket product on behalf of an insurer and also on your behalf.

3.1.6 To provide you with information regarding our other products or services which we feel may interest you. We may use your contact details for this purpose and to send you updates or news regarding Cornmarket and our services. We will seek consent from you in order to provide you with this information. You can opt out of receiving this information at any time as follows:

By writing to: Cornmarket Insurance Services Ltd, Boucher Plaza, 4-6 Boucher Road, Belfast, BT12 6HR.

By emailing: dataprotectionofficer@cornmarketinsurance.co.uk

By telephoning: 02890 44 22 00

3.1.7 To provide you with information regarding products or services of third parties which we feel may interest you and where you have consented to be contacted for such purposes.

3.1.8 To carry out our obligations arising from any contracts entered into between you and us.

3.1.9 To deliver and maintain a high quality service.

3.1.10 To allow you to access the Cornmarket website and to participate in interactive features of our service, when you choose to do so; and

3.1.11 To notify you about changes to our services, to a Cornmarket product or to the Cornmarket website.

3.1.12 Please note that telephone calls will be recorded for quality control and training purposes.

4. Disclosure Of Your Information To Other People

4.1 If you provide personal information to us, we may disclose your personal information to the following third parties:

4.1.1 Any insurer that is a party to a Cornmarket product that you have applied for or contracted for.

4.1.2 If you have indicated when applying for a Cornmarket product or at any time during your time as a user of the Cornmarket website, that you are happy to receive information or promotions from selected third parties about goods and services which may be of interest to you, you consent to third parties that we choose sending you such offers or information. You may opt out of receiving such offers or change your preferences at any time.

4.1.3 Any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries.

4.1.4 Any co-insurers of the insurers for which we act as brokers.

4.1.5 Our advisors.

4.1.6 Where you are applying or using our website to deal with a Cornmarket product in connection with a Union membership, to your union.

4.1.7 To a credit referencing agency and/or to other insurers through various databases to help us check information provided and also to prevent fraudulent claims.

4.1.8 To the prospective seller or buyer of any business or assets related to the Cornmarket website, a Cornmarket product or all or part of Cornmarket; and

4.1.9 To a third party if we are under a duty to disclose or share your personal data with that third party in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements, or to protect the rights, property, or safety of our group of companies, Cornmarket, insurers related to a Cornmarket product or others. This includes exchanging information with third parties such as Government agencies for the purposes of fraud protection and credit risk reduction; Regulators, the Police; the Revenue Commissioners; and on foot of a Court Order or Subpoena.

4.1.10 To companies that act as service providers (Data Processors) under contract with us and only process your personal information as instructed by us. Your personal information is transferred securely and is not used by other parties for any other reason. The categories of services that we use Data Processors for include: prevention of fraud document management and disposal, to facilitate the application process for cover, customer services, making and receiving payments and marketing.

4.2 We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to prevent such information being shared at the time that we notify you.

4.3 We do not disclose personal information about you to third parties (including advertisers or marketing companies) unless you have consented to that disclosure, but we may provide them with aggregate anonymised information about users of the Cornmarket website or customers of Cornmarket products. For example, we may inform an insurer advertising on the Cornmarket website that 50 men aged under 25 have clicked on their advertisement for car insurance that was displayed on the Cornmarket website on any given day, or we might inform third parties regarding the number of unique users who visit the Cornmarket website, the demographic breakdown of our Cornmarket website users or the activities that visitors to Cornmarket engage in while on the Cornmarket website. We may also use such aggregate anonymised information to help advertisers reach the kind of audience they want to target (for example, women in Dublin) when displaying advertisements on the Cornmarket website.

4.4 It may be necessary to transfer your personal information to other group companies or service providers located in countries outside of the European Economic Area (EEA). This may happen where our servers or suppliers and service providers are based outside of the EEA or where you use our services and products while visiting countries outside of the EEA. In these instances we will take steps to ensure that your privacy rights are respected such as ensuring that there is an adequacy decision made by the European Commission in place or ensuring that there are Standard Contractual Clause agreements in place which have been approved by the European Commission.

5. Security And Control Of Your Personal Data

5.1 We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Website Privacy Statement.

5.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of Cornmarket, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. You are responsible for the security of your password and our terms and conditions deal with this in more detail.

5.3 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Cornmarket; 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. You acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.

Further information on your data privacy rights is available on the website of the Data Protection Commissioner.

6. Links To Third Party Websites

6.1 Cornmarket may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates as well as third party websites to which we have no affiliation. If you follow a link to any of these websites, please note that these websites have their own privacy statements/policies and that we do not accept any responsibility or liability for these policies or for the activities on those websites.

7. IP Addresses and Cookies

7.1 We may collect information about your computer, including (where available) your IP address, alphanumeric IDs, operating system, browser type, information regarding the volume and status of data transmission, click-through statistics, the name of the domain and host from which you access the internet and the date and time you access portions of the Cornmarket Website, for system administration and statistical purposes. This is statistical data about our users’ browsing actions and patterns, and we do not use them to identify any individual, except if required by the law.

7.2 For the same reason, we may obtain information about your general internet usage by using a cookie file (which may include flash, marketing or analytics cookies) which is stored on the hard drive of your computer.

Cookies contain information that is transferred to your computer’s hard drive. On revisiting the Cornmarket website our computer server will recognise the cookie, giving us information about your last visit. They help us to improve the Cornmarket website and to deliver a better and more personalised service for you.

Cookies enable us:

7.2.1 To estimate our visitor size and usage pattern.

7.2.2 To store information about your preferences and so allow us to customise the Cornmarket website according to user or visitor preferences.

7.2.3 To enable us to tailor the advertisements you see on third party sites by understanding what interests you on our sites, such as the pages you view. We don’t combine this information with other personal information you provide us with; and

7.2.4 To speed up your use of the Cornmarket website and enquiries made of the website.

7.3 You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access or use certain parts of the Cornmarket website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Cornmarket website. For information on how to control your cookies go to www.allaboutcookies.org.

8. Updating Your Personal Data

8.1 You agree to keep Cornmarket and any insurer with which you have contracted for a Cornmarket product informed of any changes to your personal data provided to us and them.

9. Your Rights In Relation To Your Personal Data

9.1 You have the following data protection rights

9.1.1 The right to the information set out in Cornmarket’s Data Privacy Notice available at www.cornmarketinsurance.co.uk/data-privacy-notice.

9.1.2 The right to restrict or object to the processing of your personal data held by Cornmarket;

9.1.3 The right to correct and update your personal data held by Cornmarket;

9.1.4 The right to delete your personal data held by Cornmarket and to be forgotten;

9.1.5 The right to data portability;

9.1.6 The right to withdraw any consent you may have provided to Cornmarket.

9.1.7 The right to access your personal data held by Cornmarket.

9.2 You can exercise the above rights set out in sections 9.1.1 to 9.1.7 at any time by writing to the Cornmarket Data Protection Officer, Cornmarket Insurance Services Ltd, Boucher Plaza, 4-6 Boucher Road, Belfast, BT12 6HR or emailing dataprotectionofficer@cornmarketinsurance.co.uk. We will respond to your request within one month. This period may be extended for a further 2 months. If we need this extra time to deal with your request, we will notify you of the fact that there will be a delay and the reasons for it within a month of your request being made. Likewise, if we have reason to refuse your request, we will notify you within a month of the refusal and the reason for it.

9.3. If you are not happy with how we have processed your personal information or handled your privacy rights, you also have the right to complain to the Data Protection Commission by contacting them using the details below:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 0303 123 1113 or 01625 545 745

Fax: 01625 524 510

Web: https://ico.org.uk/concerns/

10. Changes To Our Website Privacy Statement

10.1 Any changes we may make to our Privacy Statement in the future will be posted on this page and, where appropriate, notified to you by e-mail. You should visit this page periodically to review any changes to the Website Privacy Statement.

10.2 Questions, comments and requests regarding this Website Privacy Statement are welcomed. Please send your query by post to: Cornmarket Data Protection Officer, Cornmarket Insurance Services Ltd. Boucher Plaza, 4-6 Boucher Road, Belfast, BT12 6HR. You may also email

dataprotectionofficer@cornmarketinsurance.co.uk

This Website Privacy Statement is effective from 25th May 2018.

Cornmarket Insurance Services Ltd is a wholly owned subsidiary of Cornmarket Group Financial Services Ltd. Cornmarket Group Financial Services Ltd is a member of the Irish Life Group Ltd. which is part of the Great-West Lifeco Group of companies.

Cornmarket Insurance Services is authorised and regulated by the Financial Conduct Authority (FCA) under firm reference number 308099. You may check this on the Financial Services Register by visiting the FCA’s website, https://register.fca.org.uk/ or by contacting the FCA on 0800 111 6768.