Privacy policy

Introduction

Xenia respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data which you provide to us, or which we obtain, when providing services to you, when you use our website xeniabroking.com, or when we deal with you in the course of our business.

This policy applies to personal data we hold relating to policy holders, professional contacts and other third parties. Depending on who you are, and how you interact with us, only some aspects of this policy may apply to you.

Who are Xenia?

Xenia Broking Group (“Xenia”) is made up of the following companies:

For simplicity, references to “we” “us” or “Xenia” shall mean Xenia Broking Group Limited and all of its brands and the companies listed above.

Changes to this policy

We may update this privacy policy from time to time – you can find our latest policy here or by asking us for a copy.

  1. IMPORTANT INFORMATION

Xenia is the controller and responsible for your personal data.

We have appointed a data privacy manager 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 data privacy manager using the details set out below.

Contact details

Our full contact details are as follows:

Address: Xenia, 52-56 Leadenhall Street, London, EC3A 2EB

Telephone Number: 0203 011 5700

Email address: [email protected]

Third-party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE DATA WE COLLECT ABOUT YOU

We collect, use, store and transfer the following data:

Sensitive Data

We may also collect, store and use the following particularly sensitive categories of personal data:

Details of how we use this information are set out in section 6.

Aggregated Data

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 Technical 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.

Failure to provide data

Where we need to collect personal data by law, or under the terms of a contract we have with you, or in order to incept a policy for you or your client, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, or to carry out the functions you are asking us to. In this case, we may have to cancel a policy or service you have.

  1. HOW WE COLLECT YOUR DATA

We collect your data from different sources:

  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Lawful basis for processing including basis of legitimate interest

To register you as a user on one of our websites

Necessary for our legitimate interests (to assist policy holders in requesting and managing policies online)

To provide services to you and carry out your instructions in connection with our services.

Performance of a contract with you

To share information with your (re)insurer and other professional advisors for the purposes of them providing services to you

Necessary for the legitimate interests of a third party (to allow your advisors to provide services to you).

To administer policies of insurance, including the transfer and receipt of premiums and commissions

Necessary for our legitimate interests (to carry out the services we are contractually required to provide for the benefit of policy holders and insurers)

Necessary for the legitimate interests of a third party (to allow brokers and/or insurers to provide a service or policy which you have requested)

To administer review, manage and assess claims made by policy holders on policies of insurance

Necessary for our legitimate interests (to carry out services we are contractually required to provide, for the benefit of policy holders and insurers)

To make payments to policy holders in connection with claims on policies of insurance

Necessary for our legitimate interests (to carry out services we are contractually required to provide, for the benefit of policy holders and insurers)

To screen details of policy holders against lists of individuals subject to governmental or regulatory sanctions.

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to operate our business in accordance with regulatory requirements;

To manage queries relating to services we have provided to you

Performance of a contract with you

Necessary for our legitimate interests (to be able to respond to queries about our services)

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy

Asking you to leave a review or take a survey

Performance of a contract with you.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to keep our records updated and to study how brokers and policy holders use our products/services).

To enable you to partake in a competition or complete a survey

Necessary for our legitimate interests (to keep our records updated and to study how brokers and policy holders use our products/services)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

Necessary to comply with a legal obligation.

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Necessary for our legitimate interests (to study how brokers and policy holders use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, broker and insured relationships.

Necessary for our legitimate interests (to define types of brokers and policy holders for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Consent (where you have provided positive consent)

Necessary for our legitimate interests (to develop our services and grow our business)

To invite you to networking and professional events, and to inform you about developments in our business or the insurance sector more widely

Consent (where you have provided positive consent)

Necessary for our legitimate interests (to develop our services and grow our business).

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.

In addition, we may process your personal data without your knowledge or consent, where this is required or permitted by law.

Marketing

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us in respect of our business and our services if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

We do not share your contact details with any third party for the purpose of that third party sending marketing.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting use using the details above at any time.

Automated Decision Making

We sometimes make decisions about you using only technology, or “automated decision making”, where none of our employees or any other individuals have been involved. For example, we may to this to decide whether to offer to issue a policy of insurance to you, the premium that is payable for any policy of insurance offered to you, the risk involved of offering a policy of insurance, or whether offer you credit.

The criteria that we apply to such decisions will differ depending on the policy of insurance and the criteria specified by the insurance company offering that policy of insurance.

As a result of this type of decision making, you may be offered or declined a policy of insurance, the terms of your offer may be determined, or your request for a policy of insurance may be referred to one of our underwriters for further consideration.

Cookies when using our website

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We use Google Analytics software to collect information about how you use our website. We do this to help make sure the website is meeting the needs of its users and to help us make improvements.

Google Analytics stores information about:


We don’t collect or store your personal information (for example your name or address) so this information can’t be used to identify who you are.

We don’t allow Google to use or share our analytics data.

Google Analytics sets the following cookies:

Universal Analytics

Name

Purpose

Expires

_ga

This helps us count how many people visit our website by tracking if you’ve visited before

2 years

_gid

This helps us count how many people visit our website by tracking if you’ve visited before

24 hours

_gat

Used to manage the rate at which page view requests are made

10 minutes


Google Analytics

Name

Purpose

Expires

_utma

Like _ga, this lets us know if you’ve visited before, so we can count how many of our visitors are new to our website or to a certain page

2 years

_utmb

This works with _utmc to calculate the average length of time you spend on our website

30 minutes

_utmc

This works with _utmb to calculate when you close your browser When you close your browser

30 minutes

_utmz

This tells us how you reached our website (for example from another website or a search engine)

6 months

  1. HOW WE USE PARTICULARLY SENSITIVE DATA

Where we collect you particularly sensitive data, we may use it in the following ways:

For some policies of insurance, we collect data about your health. We collect this directly from information you provide to us. We may also collect data about your health in an emergency situation from your doctors and healthcare providers and advisers, and also from loss adjusters who collect information on our behalf.

We use this data for the purpose of determining whether we can offer to issue a policy of insurance to you, and if we do, the terms upon which we offer the policy to you, including the level of premium. We will also use it in connection with assessing any claims that you make

Where we collect and use this data, we do so with your consent.

For some policies of insurance, we may collect data about your criminal convictions directly from you, from proposal forms completed by brokers or third parties you have interacted with, and from third party search providers, such as Experian, and government sanctions lists.

We use this data for the purpose of determining whether we can offer to issue a policy of insurance to you, and if we do, the terms upon which we offer the policy to you, including the level of premium.

We may also receive details of convictions or offences or alleged offences when we carry out searches against sanctions lists. Where your name appears on a sanctions list, we may not be able to provide a policy of insurance to you.

Where we collect and use this data, we do so as permitted by law.

In both of the above cases, we have in place an appropriate policy and safeguards which we are required by law to maintain when processing data regarding your health or criminal convictions.

  1. CREDIT REFERENCE AGENCIES

If you apply for premium finance so that you may pay your premium in instalments, we will send your details to a premium finance provider who will process your application. That premium finance provider may perform credit and identity checks on you with one or more credit reference agencies (CRAs) as part of processing your application.

When CRAs receive a search request they may place a search footprint on your credit file that may be seen by other lenders. CRAs may share and use your information with other organisations.

  1. DISCLOSURES OF YOUR PERSONAL INFORMATION

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above:

  1. INTERNATIONAL TRANSFERS

We may transfer your personal data to third parties providing services to us who are based outside of the European Economic Area (EEA). This includes parties providing IT administration services and hosting services, and parties providing assistance with managing our marketing databases.

Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  1. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will usually keep your data for between 6 years and 10 years from inception of the last insurance policy that you incepted with us. For full details of our retention periods, please contact our data privacy manager.

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager.

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.

Complaint to the ICO

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.

Your legal rights

Your legal rights are as follows: