Privacy Policy

How to contact us

For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller, we use (or process) the personal data we hold about you in accordance with this privacy notice.

Data Controller: Head of Compliance, Freedom Brokers Ltd, Eden Point, Three Acres Lane, Cheadle Hulme, Stockport, Cheshire, SK8 6RL.

Contact for queries: Head of Compliance, 0161 488 3888, compliance@action365.co.uk

This privacy notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this privacy notice as personal data or personal information and further detail of what this includes are set out in this privacy notice below.

The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected by us at all times. Please read this privacy notice carefully as it explains how we may collect and use your personal data.

What type of personal information do we need?

  • We may need personal details which will include contact and dates of birth, financial details, and Insurance details, such as your vehicle and driving history including claims.
  • For Telematics insurance contracts we need personal details relating to time, location and driving, including; time, latitude, longitude, speed, duration, distance and acceleration. We will collect event data such as accident detection, unit tampering or activation and deactivation events.
  • From the Freedom To Drive Smartphone App, which is required for telematics policies we may collect technical data and related information, including but not limited to technical information about your smartphone device, system and application software, and peripherals.
  • We will only collect what is necessary and will only keep it for as long as we are required to do in line with our data retention policy.

What other types of information do we need?

  • Under certain circumstances we may also need to obtain information about Health, Injuries or Criminal Convictions, your claims or credit history.
  • By asking us to arrange a contract of insurance for you where this involves passing information to us relating to children, you confirm to us that in doing so you are the responsible guardian of the child.
  • We also collect information from publicly available sources and third party databases made available to the insurance industry for the purposes of reducing fraud and financial crime as well as any other third party databases where your personal data may be held, provided such third parties have lawful bases on which to share such personal data with us.
    We will only collect what is necessary and protect it with appropriate security measures.

How will we use the information you give us?

We will use your information to provide you with a quotation at your request, on the basis that it is necessary to administer your insurance contract , for fraud prevention and detection, to undertake market research, product development, for statistical analysis for behavioural analysis and to develop and improve the services which we offer, or help you make a claim.

In addition, for telematics policies, we will use your information to arrange the installation of your device through our third-party supplier, to assess your driving behaviour, to provide trip information on the Freedom To Drive App, assist you in the case of an accident or for telematics research and analysis.

We may rely on one or more of the following legal bases when processing your personal data for the following purposes:

Special categories of data and criminal convictions

We may also need to collect special categories of data from you such as information about your health, personal data revealing racial or ethnic origin, religious or philosophical beliefs or trade union membership and generic data. We may also collect information on criminal convictions which we may share with third parties. The lawful basis on which we can do this is the processing is necessary for reasons of substantial public interest relating to insurance purposes.

Insurance purposes mean (a) advising on, arranging, underwriting or administering an insurance contract (b) administering a claim under an insurance contract or (c) exercising a right or complying with an obligation, arising in connection with an insurance contract, including a right or obligation arising under an enactment or a rule of law.

How we contact you about other products and services

We may from time to time process your personal data to let you know about similar products and services that may be of interest to you. This is because we value your custom and we pride ourselves in offering professional and tailored advice which meets your specific insurance needs. This includes keeping you informed on the latest insurance and industry information and details of any offers or promotions relating to the insurance services we provide to you. Our lawful basis for processing your personal data in this way is as is necessary to pursue the legitimate interests of our business, unless we have otherwise obtained your consent to do so. We may contact you by post, telephone or e-mail. You will be given the option to stop receiving any communications from us in this regard at any time however please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.

Who we pass your personal data to:

We may need to pass your personal data to other companies which may include:

  • Other companies or brands within our group of companies, for example if we are unable to provide a suitable insurance policy on request or at renewal we will check if any of our associated group companies can provide you with suitable cover
  • The insurers, intermediaries and third-party service providers that we use for the purpose of arranging and administering your insurance policy. This may also include risk management assessors, uninsured loss recovery agencies, premium finance providers and other third parties involved (directly or indirectly) in the administration of your insurance and its associated benefits
  • Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as claims handling, IT systems and administrative services and other activities set out in this privacy notice, as well as support activities such as finance and auditing services
  • Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
  • Other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid request from the police or other third-party organisation in the interest of preventing and detecting crime
  • Fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud
  • Credit reference agencies to check your credit history. This check will be recorded on your credit reference file without affecting your ability to apply for credit or other financial products
  • Third parties we use to recover money you may owe us or to whom we may sell your debt
  • Another company, if our business or part of it is bought or taken over by that company to make sure your insurance policy can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over
  • We enlist the services of MyCarNeedsA.com (MCNA) who provide you with MOT reminders at the appropriate time to help ensure your vehicle remains legally on the road. MCNA will provide MOT quotes from local garages to facilitate your MOT when it is due. The MCNA network of garages are DVSA MOT approved and consistently monitored for quality and service levels.

The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the UK and the European Union. We will only do so if there are adequate levels of protection in place as required by applicable data protection laws.

How do we obtain your information?

  • We may gather it from information you provide, by telephone, face to face, online, by email, the telematics unit in your car, from the Freedom To Drive Smartphone App, or from surveys or feedback you provide.
    We may receive it from Insurers, other insurance brokers, DVLA, industry wide databases, external third-party suppliers working on our behalf, finance providers, price comparison sites and firms handling claims.

What are my legal rights?

We will only store your data for as long as is necessary to comply with the requirements of your insurance contract(s) and any legal obligations or lawful processing conditions that may exist as a result. You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep you information. If this is the case, we’ll let you know our reasons.

You can ask us to:

  • Provide a copy of your personal information
  • Correct or delete unnecessary or inaccurate personal information
  • Restrict or to object to the use of your personal information at any time
  • Object to any automated decision, including profiling which may have been used by insurers when underwriting your quotation. Where an automated decision has been made we will advise you of this and of your rights
  • Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you
  • Where we rely on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you don’t want us to contact you again.

If you have any questions or concerns about this privacy notice or your data protection rights, please contact us using our details set out at the beginning of this privacy notice.

You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement. Further details about the ICO are available at: www.ico.org.uk.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website;

(b) status – we use cookies to help us to determine if you are logged into our website;

(c) personalisation – we use cookies to store information about your preferences and to personalise our website for you;

(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(e) advertising – we use cookies to help us to display advertisements that will be relevant to you;

(f) analysis – we use cookies to help us to analyse the use and performance of our website and services; and

(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

This privacy notice may vary from time to time so please check it regularly. This privacy notice was last updated on 17/02/2021.