Effective date: 01/06/2023
Custodian is the Data Controller and is responsible for your Personal Data.
We respect your privacy and are committed to protecting your Personal Data.
COOKIES are small files stored on your device (computer or mobile device).
DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data is or is to be, processed.
EXTERNAL THIRD PARTIES includes:
These third parties include Google Analytics, GitHub (a development platform to host and review code, manage projects, and build software), Lexis Nexis, payment processor Stripe, and other third parties from time to time which allow us to directly improve the Insurance Service and the Custodian Platform for our users.
PERSONAL DATA means data about a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).
For Custodian to provide insurance quotes, insurance policies and/or deal with any claims or complaints, we may need to collect, retain and process certain Personal Data about you as set out below.
We collect several different types of information for various purposes to provide and improve our Service to you.
We may collect, use, store and transfer different kinds of Personal Data about you while arranging insurance cover for you or managing a claim. We have grouped the Personal Data together as follows:
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, 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. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Our Policy on “Do Not Track” Signals:
We honour Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
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:
Promotional offers from us
We may use your Personal Data to contact you with insurance-related newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or by emailing at email@example.com.
Your Personal Data will never be sold on to external parties or organisations for marketing purposes.
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes (including other companies within our group). We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time.
Change of purpose
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.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we 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.
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We will also retain Technical Data for internal analysis purposes. Technical Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Many of our External Third Parties are based outside the UK so their processing of your Personal Data will involve a transfer of data outside the UK.
Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the UK.
We may disclose personal information that we collect, or you provide, to:
Companies within our group: We share your Personal Data with our group companies so that we can provide information to you about other services we offer that may be of benefit to you, to allow you to store and view your documents in one place and to provide you with a seamless experience when you use a Custodian product (whether an Insurance Service or a product offered by one of our group companies).
Service providers acting as processors who provide the Insurance Service or any part of it on our behalf, perform Insurance Service-related services or assist us in analysing how our Service is used: These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Professional advisers: who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, the Financial Conduct Authority, and other regulators and authorities based in the United Kingdom: for the purpose of complying with reporting obligations.
Insurance market participants: Insurance involves the use and disclosure of your Personal Data by various insurance market participants. We will only share your Personal Data with other insurance market participants if it’s required for a specific purpose and we have a lawful basis to do so.
Our Principal (Bluefriars Brokers Limited, which is authorised and regulated by the Financial Conduct Authority (No.604987)), your insurance broker (where applicable), service providers, sub-contractors and agents: we share you Personal Data with them in order to administer your account and the products and services provided to you by us now or in the future, including but not limited to our payment processors and electronic documentation providers; and
Our distribution partners, which includes any company that distributes, advertises or recommends insurance policies on our behalf: we share your Personal Data with them so that they can distribute insurance policies on our behalf.
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities. We are legally required to have certain processes in place with regards to anti-bribery and corruption, money laundering and fraud. If any criminal offence is detected or suspected, we may share data with financial and regulatory organisations (e.g. the Financial Conduct Authority, the Information Commissioner’s Office) or law enforcement agencies (e.g. fraud prevention agencies, anti-money laundering agencies and courts) to assist them
If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
We are committed to ensuring that your information is secure. All Personal Data provided to us is stored on secure servers and only accessed and used in line with our data protection policies and procedures. Your Personal Data will be accessed by our employees or authorised third parties who require the information for their business purposes.
No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If you'd like to learn more about your rights, please see the website of the Information Commissioner's Office.
You generally have the following rights, which you can usually exercise free of charge:
If you have provided us with a consent to use your Personal Data, you have a right to withdraw that consent easily at any time. Withdrawing a consent will not affect the lawfulness of our use of your Personal Data in reliance on that consent before it was withdrawn.
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.
If you wish to exercise any of the rights set out above or have any other queries or concerns, please don't hesitate to contact us at firstname.lastname@example.org.
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 could 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 could 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.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Services are not intended for use by children under the age of 17 (“Children”).
We do not knowingly collect personally identifiable information from Children under 17. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
Full name of legal entity: Custodian Financial Services Limited
Email address: email@example.com
Postal address: FAO: DPO, Custodian Financial Services Limited, Palliser House, Palliser Road, London, England, W14 9EQ
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.
Version 0.1 - June 2023