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Privacy and Cookie Policy

May 2018

Vast Visibility Limited - ICO registered number: Z2630581

Data Protection

Confused.com Motorhome and Caravan Insurance price comparison service is administered by Vast Visibility Ltd, 8 Princes Parade, Liverpool, L3 1DL (company number 05866769) which is registered by the Financial Conduct Authority under Firm Reference Number 566973.

We respect your privacy and are committed to protecting your personal data. We take Data Protection seriously because we want you to feel confident about the privacy and security of the personal information you input on our website. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. We follow strict security procedures in the storage and disclosure of your information as required by law.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are

This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website. We provide a price aggregation and comparison service to assist you to obtain quotations for insurance.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

To be able to supply our service, we have to collect and process personal information about you, including potentially sensitive information surrounding medical conditions and convictions. We have to disclose that information to the brokers or insurers in order to obtain a quotation and afterwards if you take out a policy. This processing is necessary for the performance of the contract and by proceeding you are providing explicit consent for us to do so.

The provision of our services necessarily involves linking with third party websites who receive your personal information for the purposes of providing quotations. These 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.

The data we collect about you

The type of personal data, which could include sensitive data (e.g. marital status, convictions and medical conditions), that we will be collecting are:

  • Biographical data such as user’s first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, address, e-mail address, phone number, convictions and medical conditions.
  • Information that is automatically collected such as internet protocol (IP) address, unique device identifiers, login information (if applicable), URL clickstream to, through and from the site (including date and time); insurance services viewed or searched for, length of visits etc
  • Usage Data includes information about how you use our website, products and services
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Information which is received from other sources such as other websites or online services linked to by Vast Visibility Limited

Any personal information that we retain will be held in strictest confidence.

The Brokers and Insurers you are introduced to will have their own Privacy Policies. They may differ from ours so you should check how they will use your data.

They and the other providers linked to our service are only entitled to use your data for the purpose of providing you with insurance quotations on the requested product and for internal processes such as fraud prevention or analysis (such as monitoring market trends, customer demographics or pricing analysis). They are not entitled to use your information for general marketing purposes unless you have consented to this directly with them. We will not overwrite any existing marketing preferences you have previously set up with product providers.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice

By submitting information into our site, you consent to the processing of this data about you by the product providers and us.

How we use your personal data

Your personal information is used for the purpose of allowing you to receive insurance quotes, informing you of other products and services we offer, fulfil any promotions that we operate and for tracking any purchased policies.

As part of our service, we may also contact you at each anniversary of your completed quote in order to provide you with a new set of quotes that could be for used for your next renewal. We do this by resubmitting the data that we hold on you to get updated prices from our providers.

As part of the insurance quotation process, if you choose to receive a quotation you will be sent an email, sms and in some cases will receive phone calls from insurance brokers. This part of the process is mandatory, however to stop receiving additional emails from us you can update your own contact preferences by using the unsubscribe system.

We may also use your data for research purposes, data analysis and enhancement, remarketing and for delivering advertisements relevant to you on third party websites.

If you give us your driving licence number when obtaining an insurance quote, it may be submitted to the DVLA MyLicence service by us and /or our providers in order to verify the status of your (or any named driver's) licence and entitlement along with any relevant restriction information, endorsement and/or conviction data. These searches will not show on your (or your named driver's) DVLA driving licence record. Carrying out these searches may help insurers prevent fraud and they reduce the likelihood of negligent misrepresentation and non-disclosure of important information.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform our services as set out above. This will include sending you insurance renewal reminders, unless you instruct us otherwise
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Credit and Validation Searches

During the process of generating a quote some insurance/service providers, including ourselves, might make credit, identity and/or fraud checks and by using our service you authorise them/us to do so. For example; this may involve:

  • Credit reference agencies checking details against public or private sources, and using these details to help other companies verify you. The insurance checks are registered as general insurance searches and may be viewed by other companies when you apply for credit or insurance.
  • Records of searches being kept, which may be linked to records of persons financially associated with you.
  • If you give inaccurate details or fraud is suspected this may be shared with fraud prevention agencies, and may also be used by other organisations to make decisions about you and others in your household on credit, insurance (including claims), debt tracing, and to prevent crime.

Some insurance/service providers, including us, may also carry out checks against data they already hold on you (or is held by the company whose brand they administer the product for, or members of their group of companies) such as data from existing products, account data or loyalty scheme data. They may use this data to help them assess and rate your application for a quote and determine your premiums. They may also pass this data to their insurance underwriters for these purposes where applicable.

We may use and share your information to help them and us:

  • assess financial and insurance risks;
  • develop our services, systems and relationship with you;
  • prevent and detect crime.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at : customer.services@vastvisibility.co.uk.

If we wish to use your personal data for an unrelated purpose, for example marketing of third party products and information we will obtain your separate specific consent will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Your personal data

Vast Visibility Ltd, who for the purposes of the GDPR are the Data Controller administer the website, comply with and are registered under the data protection laws in the United Kingdom and take all reasonable care to prevent any unauthorised access to your personal data.

In the event of the sale of the business, personal data held by Vast Visibility about customers will be transferred along with other assets to the new owners. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice

We reserve the right to alter or modify this privacy policy statement at any time and in response to changes in applicable data protection and privacy legislation. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not transfer your personal data outside the European Economic Area (EEA).

Monitoring

Monitoring or recording of your calls, emails, text messages and other communications may take place in accordance with UK law, and in particular for business purposes, such as for quality control and training; processing necessary for the entering into or the performance of a contract; to prevent unauthorised use of our telecommunication systems and web sites; to ensure effective systems operation; to meet any legal obligation; in order to prevent or detect crime. Please visit the following website for further information www.ico.org.uk

If you have any enquiry about our data protection and privacy policy or practices, please email us customer.services@vastvisibility.co.uk.

Our obligations to you

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Data Protection Officer

Vast Visibility Limited

8 Princes Parade, Princes Dock, Liverpool, L3 1DL

Email address: DPO@vastvisibility.co.uk

Telephone number: 0800 044 3731

If at any point you believe that the information that we hold on you is incorrect you can request to see this information and even have it corrected or deleted. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance

Subject Access Request

If you require a copy of the information we have concerning you, please make a Subject Access Request to the Data Protection Officer at Vast Visibility Limited, 8 Princes Parade, Princes Dock, Liverpool L3 1DL. Subject to security validation as to the identity of the requester results will be presented as soon as reasonably practical and in any event within one month of the request.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfill the purposes outlined in this Privacy Policy or until you request it is deleted.

In some circumstances you can ask us to delete your data: see Request erasure below for further information. Even if we delete your personal information it may persist on encrypted backup or archival media for legal, tax or regulatory purposes

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Data & site security

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

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We use the industry standard secure sockets layer (SSL) 256-bit encryption technology to ensure that all your personal and transactional information is encrypted before transmission. To check that you are in a secure area of our site look at the bottom of your browser and you will see a closed padlock. All this technology and our policies are to safeguard your privacy from unauthorised access/improper use and we will continue to update these measures as new technology becomes available.

IP addresses

Your IP address is a series of numbers which identify a computer (not a person) on the internet. We use IP addresses to help diagnose possible service interruptions and administer our service and website.

Cookies & our cookie policy

A cookie is a small text file that is placed on your hard disk by a web page server. Cookies cannot be used to harm your computer, they cannot run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can only be read by a web server in the domain that issued the cookie to you.

Our cookies don't store sensitive or personally identifiable information such as your name, address or credit card details: they simply hold a unique ‘key’. We do use encrypted information gathered from them to help improve your experience of the site. For example, they help us to identify and resolve errors, or to help us work out the best user interface for our insurance process.

Cookies can be referred to as session cookies or persistent cookies, depending on how long they are used:

  • Session cookies only last for your online session and disappear from your computer or device when you close your browser.
  • Persistent cookies stay on your computer or device after the browser has been closed and last for the period of time specified in the cookie. These persistent cookies may be checked each time you visit the site where the cookie was generated or, in the case of third-party cookies, from another site that also uses the same service.

Below is a list of the main cookies we use, and what we use them for.

Essential cookies

These are cookies that are enabled for all our customers to ensure that our website works properly.

Cookie nameCookie policy
ASP.NET_SessionId These cookies allows our web servers to respond to your actions on the website such as logging in or running an insurance quote. The website wouldn't work for you without them.
Google Analytics These cookies allows us to collect anonymous information about how visitors are using our website including where they drop-off and which device/browser they came from.
Google Analytics (Demographics and Interest Reporting) This cookie allows us to use anonymous data from Google's interest based advertising or third party audience data, including demographic information about our visitors including gender, age group and interests.
Visibility Statistics We use Visibility Statistics to analyse how users interact with our website and the content found within it. Mouse movements, mouse clicks, page scrolling and text entered into search boxes and website forms may be recorded for statistical reporting purposes and to improve site usability. The data compiled is for internal use only.
Google AdWords, DoubleClick, Bing Ads, OMG, Affiliate Window, VE Interactive, Marin, Facebook These third party cookies show us how you found our website and which website you came from. This helps us know which of our online marketing channels is most effective. They also allow us to reward some external websites for directing you to us.
Other Application Cookies Visited, source_referer,source_refid questionSetStart, questionSetFinish These are cookies that are set by our application. They are there so that we can understand how long our platform takes to provide you with quotes, the marketing source used to get a quote and if you have been to our site before.
New Relic (JSessionID) This cookie is set by New Relic (www.newrelic.com) and is used to help us understand if our application has any errors or programming issues.

Non-essential cookies

We use these cookies for online marketing purposes, the website works without them but we can't improve our online marketing effectiveness without them. These cookies can be disabled if you don't want to use them

Cookie nameCookie policy
AdWords Retargeting These third party cookies let us serve personalised adverts to you when you're browsing other websites e.g. reminding you to return to complete your quote. You can control advert personalisation on Google and partner websites here: https://adssettings.google.com/
DoubleClick Retargeting These third party cookies let us serve personalised adverts to you when you're browsing other websites e.g. reminding you to return to complete your quote. You can control advert personalisation on Google and partner websites here:https://adssettings.google.com/
Facebook Retargeting These third party cookies let us serve personalised adverts to you when you're browsing Facebook e.g. reminding you to return to complete your quote. You can control advert personalisation on Facebook here:https://en-gb.facebook.com/ads/settings

The advertisements that you see displayed on our sites are delivered on our behalf by certain third party advertising companies. No information which identifies you, for example your name, address, email address or telephone number, is used to provide this advertising. In order to display advertising most likely to be relevant to you, these third party advertisers may place or recognize a unique cookie on your browser. This cookie does not collect personal information about you nor is it linked to any identifiable information about you. By using the Services you are consenting to the use of these third party cookies for these purposes.

Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data 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 processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

  • You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

  • We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response

Time limit to respond

  • We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated

Removing data

  • If you wish unsubscribe from some or all of our services you can do so using the following link: unsubscribe system
  • If you would like us to remove any personal information from our records, then please email us at: customer.services@vastvisibility.co.uk Please supply your full name, address and date of birth when contacting us in order that we can locate your file. Removal of your data from our records will mean that the renewal reminder service that we provide will no longer take place and you should take alternative steps to ensure that your insurance cover does not unknowingly expire. We will make all reasonable efforts to delete your information from our files

Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at: customer.services@vastvisibility.co.uk

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal Third Parties

Other companies in the group of companies to which Vast Visibility belongs and who are based in the UK.

External Third Parties

Service providers acting as processors based in the UK who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

Insurers and insurance brokers who provide quotations for insurance via the website based upon personal information.

Data enrichment organisations as used by insurers for the purposes of providing quotations, including electoral roll search organisations, credit reference and credit scoring agencies.

More help
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