Business privacy policy – General

Rightpath Insurance Solutions Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our:

• Customers;
• Suppliers;
• Employees;
• Any other individual/group we hold personal data about

We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of our Site AND/OR you will be required to accept this Privacy Policy when registering a claim. If you do not accept and agree with this Privacy Policy, you must stop using our Site immediately and you should not provide any personal data.

1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:

“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

2. Information About Us
Our Site is owned and operated by Rightpath Insurance Solutions Limited registered in England under company number 06411430, Registered address: New Century House, 17-21 New Century Road, Laindon, SS15 6AG, UK.

Data Protection Officer: Matthew Tomkins
Email address: compliance@rpisolutions.com
Telephone number: 020 8667 1600
Postal Address: PO Box 6430, Basildon SS14 0QT, UK

3. What Does This Policy Cover?
This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

This Privacy Policy also applies to your use of our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
• The right to access the personal data we hold about you. Part 13 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for particular purpose or purposes.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. What Data Do We Collect?
We may collect some or all of the following personal data and non-personal data (please also see Part 14 on our use of Cookies and similar technologies):

• Name;
• Date of Birth;
• Gender;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Payment information;
• Information about your preferences and interests;
• address;
• Claims and insurance information;
• Health information.

Your personal data may also be obtained from the following third parties:

• Insurance broker;
• Medical assistance company;
• GP;
• The agent who sold your policy;
• Insurers;
• Third parties related to the claim (e.g. a close relative).

7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:

• Assess and administer claims, including requesting your feedback on our performance;
• Your personal details are required in order for us to enter into a contract with you;
• Communicating with you. This may include responding to emails or calls from you;
• Internal record keeping and job applications;
• We may use the information to improve our products and services;
• We will also use information collected to safe-guardagainst fraud and money laundering. We are required to report details of some suspicious activities to the National Crime Agency (NCA)

We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to request opt-out.

Third Parties including: The Financial Conduct Authority, The Financial Ombudsman Service, The Association of British Insurers, Foreign and Commonwealth Office, UK Passport Office, Australian Health Service, Civil Aviation Authority, The NHS and the Association of British Travel Agents whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We use the following automated system for carrying out certain kinds of decision-making AND/OR profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more or to launch an appeal into the decision, using the details in Part 15.

The following automated decision-making methods may be used for processing your personal data:

• Claims assessment decision, including profiling based on potential fraud indicators

All automated decisions should be made in line with your policy terms and conditions and you have the right to appeal these decisions.

8. How Long Will You Keep My Personal Data?
We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply with our legal and regulatory obligations. The time period we retain your personal information for will differ depending on the nature of the personal information and what we do with it. How long we keep personal information is primarily determined by our regulatory obligations. We typically keep policy and claims records for up to 10 years from the end of our relationship with you. In some cases, such as if there is a dispute or a legal action we may be required to keep personal information for longer.

9. How and Where Do You Store or Transfer My Personal Data?
We may share your data with external third parties, as detailed below in Part 10, that are based outside of the United Kingdom. The following safeguard is applied to such transfers:

• We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the following website: "https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en " (European Commission).

Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country. The security of your personal data is essential to us, and to protect your data, we take important measures, including making sure the standard of their data protection is equivalent to ours.

10. Do You Share My Personal Data?
We may sometimes contract with third parties to supply certain products AND/OR services. These include:

Sub Processor	Type of Data Shared	Reason
ATICS	Claim data	Cloud service provider
Amazon Web Services	Claim documents	Secure file storage and cloud services provider
Go Daddy	Cookies and website data (please see Section 14 for our use of Cookies)	Market research and business development
Office 365	Internal company data	Emails and team collaboration
HSBC Net	Payment details (bank account number/sort code and name of beneficiary)	Payment processing
Vitesse	Payment details (bank account number/sort code and name of beneficiary)	Payment processing
Stripe	Payment details (bank account number/sort code and name of beneficiary)	Allows us to make and receive payments.
Google Places API	Customer address	Validates address during claim set up.
Google Maps API	Customer address	Autocompletes address details based on input of first line of address during claim set up.
Loqate	Account number and sort code	Validates bank account information and returns name of bank
Rightpath Solutions Ltd.	Personal data (claimants and employees), claimant's health information, claimant's insurance data	Group level network, telecomms, claim systems and system administration, compliance, security, marketing. Claims services.

We may also share your data with the National Crime Agency or third party claims administrators/investigators for the purpose of fraud investigation or to comply with our legal and regulatory obligations

We may also contact your doctor or an independent doctor working on our behalf to confirm cover in line with the terms and conditions of your policy wording.

We may also share policy and/or claim data with other insurers/third party claims administrators/medical assistance companies/cost containment facilities for the purposes of;

• Policy validation
• Insurer referrals
• Assistance company referrals
• Subrogation
• Cost containment

In some cases, those third parties may require access to some or all of your personal data that we hold. We do not disclose your information to anyone outside Rightpath Insurance Solutions Ltd except:

• where we have your permission; or
• where we are required or permitted to do so by law or by regulatory bodies; or
• to other companies who provide a service to us or you; or
• where it is necessary for the performance of an agreement we have with you; or
• fraud prevention purposes; or
• where we may transfer rights and obligations under this agreement.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the United Kingdom, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by calling us on the number mentioned in Part 15 or on the claims form we send out to you.

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?
In most cases we will not be able to assess a claim without you providing us with certain personal data.

You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged of £10.00 to cover our administrative costs in responding.

We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. These Cookies are not integral to the functioning of our Site and your use and experience of our Site will not be impaired by refusing consent to them.

All Cookies used by and on our Site are used in accordance with current Cookie Law.

Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details: For the attention of:

The Data Protection Office
Email address: compliance@rpisolutions.com
Telephone number: 020 8667 1600
Postal Address: PO Box 6430, Basildon SS14 0QT, UK.

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.