This website is maintained by Davies Group Ltd. This privacy statement applies to information we may collect from you when you visit the www.davies-group.com website. It does not apply to any sites we link to. We have a legal duty to protect any personal information we collect and take appropriate measures to do so. All information is handled lawfully in accordance with the Data Protection Act 2018 (as amended from time to time). When you visit our website, some details are recorded from your web browser for statistical purposes only. This information helps us in finding out which pages are of most interest and how many visitors our website serves. Cookies are used where you have identified yourself to the site on the login pages so that the site can provide you with additional functionality for the duration of your visit to the website. A cookie is a small text file written to your hard drive that contains information about you. Cookies do not contain any personal information about users. Once you close your browser, the cookie simply terminates. We use cookies to process and identify data so that we can personalise your experience of our website. You can set your browser to refuse cookies and you will still be able to use our website. In compliance with EU legislation, the following table lists the use of cookies on this web site:

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. Any personal information is held safely with our security systems preventing unauthorised access. When you complete a form that requests personal information or email us, you will provide information with which we can identify you. This information will be treated in confidence and only used for the purposes for which it was provided. Davies Group Limited will not sell or rent your personally identifiable information to anyone. If we change our Privacy Policy, we will post any changes on this website so that you are always aware of how we use your information.

All telephone calls maybe recorded for the purposes of training and monitoring and to comply with the Data Protection Acts requirement to provide ‘Fair Processing’ information.

Davies Group are committed to protecting the privacy of our users, clients and customers. This privacy statement explains how we use any personal information we collect about you when you use this website. It is also intended to assist you in making informed decisions when using our website and our products and services.

All your personal Information shall be held and used in accordance with the General Data Protection Regulation (GDPR). If you want to know what information we collect and hold about you, please email us at dpo@davies-group.com or by writing to the Data Protection Officer, Davies Group, 3rd and 4th Floors, No.2 Smithfields, Stoke-on-Trent ST1 3DH, UK

The type of personal information we collect

We currently collect and process the following information:

• Personal identifiers, contacts and characteristics (for example, name and contact details)
• Sensitive personal data including up to date medical diagnoses information may be held, used and processed for the purpose of providing the services offered by the Davies Group.

How we get the personal information and why we have it

The personal data which we process may be collected from a number of sources including, but not limited to, the following:

• Your Insurer/Underwriter
• Our clients
• 3^rd parties
• Third party data providers/search systems
• Experts
• Insurance industry databases
• Law enforcement agencies
• Insurance companies
• Social media
• Loss adjusters and claims investigators
• Intermediaries (claims management suppliers etc.)
• Industry regulators, including but not limited to the FCA, ICO and FOS
• Fraud prevention agencies and organisations

During the course of our service, we may collect further data from you directly in order to progress your claim.

How we store your personal information

Your information is securely stored within our secure data centres and servers.

Depending on the type of the data we hold, and the type of claim it relates to, the length of time your data is stored for may vary. This is detailed in the table below.

When information has passed the retention period, your data will be disposed of in accordance with our Data Disposal and Destruction Policy.

How do we protect your information?

The information which you provide to the Davies Group will be used within the group of companies for processing your Claims and customer services and for the administration of any of the Groups related products and services of which you and any other person on your policy avail. Data may also be used for statistical analyses and the Davies Group may share information with law enforcement bodies/ fraud prevention agencies for the purpose of preventing or detecting fraud. We may share your data with trusted third parties who process data on our behalf. We also share your data with insurers to verify your cover, and with state bodies as required by law. Sensitive personal data including up to date medical diagnoses information may be held, used and processed for the purpose of providing the services offered by the Davies Group. By utilising the services of the Davies Group you confirm that you explicitly consent to the Davies Group processing your personal data for the purposes described above, and have explained to each person who is included on your policy why we may ask for this information and what we will use it for. You also confirm that each person has agreed to this. You have the right, subject to certain exemptions, to access any personal data that we hold about you and to have inaccuracies corrected. If you wish to avail of these rights, please write to the Data Protection Officer, Davies Group, 3rd and 4th Floors, No.2 Smithfields, Stoke-on-Trent ST1 3DH, UK

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing your information are:

• Your consent. You are able to remove your consent at any time. You can do this by contacting dpo@davies-group.com
• We have a contractual obligation.
• We have a legal obligation.
• We have a vital interest.
• We need it to perform a public task.
• We have a legitimate interest.

We maintain the highest standards of security; however, the transmission of information via the internet is never completely secure. As a result, whilst we strive to protect your personal information, we cannot ensure or warrant the security of any information which you send to us, and you do so at your own risk. Once we have received your information we will use strict procedures and security features to prevent unauthorised access or loss.

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. 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, for example for the purpose of the detection and prevention of crime.

How can you access and correct your information?

You may instruct us to provide you with details of all of your information that we collect and maintain in our database by submitting a Subject Access Request via post, Phone or via the website. The address to send a request is; Data Protection Officer, Davies Group, 3rd and 4th Floors, No.2 Smithfields, Stoke-on-Trent ST1 3DH, UK

Any request for information is free of charge but Davies Group can refuse or charge for requests that are manifestly unfounded or excessive.

Your rights in regard to your personal information

Under GDPR, individuals now have increased rights in regard to their personal data. Please see below an outline of your rights and if you wish to contact us to discuss or amend the data we hold, please contact us dpo@davies-group.com or by writing to us at; Data Protection Officer, Davies Group, 3rd and 4th Floors, No.2 Smithfields, Stoke-on-Trent ST1 3DH, UK

• Right to be Informed – You have the right to know how we collect and use your personal information
• Right of Access – You have the right to ask us for copies of your personal information.
• Right to Rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Right to Erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Right to Restrict Processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Right to Object to Processing – You have the right to object to the processing of your personal information in certain circumstances.
• Right to Data Portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• The Right not to be Subject to Automated Decision-Making Including Profiling
• In the event of a data breach – If the Davies Group were to experience a data breach they would within 72hrs upon realising a breach had occurred and where feasible, report certain types of personal data breach to the relevant supervisory authorities. If the breach is likely to result in a high risk of adversely affecting our customer’s individual rights and freedoms, we will also inform those individuals without undue delay.

As per Article 12 of the GDPR, you are not required to pay any charge in order to exercise your rights. If you make a request, we have one month to respond to you – though this can be extended by a further 2 months when taking into account the complexity or number of requests. If this is the case, we would inform you of any such extension within one month of receipt of the request and state the reasons for the delay.

If we are unable to identify you or locate your data, we may ask you to provide further information to assist us in doing so. If your request is manifestly unfounded or excessive, we may charge a reasonable fee to account for the administrative costs of providing the information or refuse to act on the request.

Please contact us at dpo@davies-group.com or please write to the Data Protection Officer, Davies Group, 3rd and 4th Floors, No.2 Smithfields, Stoke-on-Trent ST1 3DH, UK if you wish to make a request.

Automated Processing and Decision Making

In some circumstances, Davies Group may use automated processing and decision making (where a decision is made by automated means without any human involvement) where necessary. When doing so, Davies Group ensures that this is necessary for the entry into or performance of a contract, authorised by domestic law applicable to the data controller or based on your explicit consent.

Our automation technologies include:

• Robotic Process Automation – Virtual Workers automate the copy and pasting of information from system one into system two
• Self-Service – The self-service platform allows humans to directly interact with an RPA process, enabling human-in-the-loop processing of information
• Artificial Intelligence (AI) and Machine Learning – Can enable Virtual Workers to learn and understand the data presented and improve effectiveness
• Intelligent Automation Digital Assistant – An AI supervisor that automatically manages, tracks and orchestrates virtual worker schedules and activities
• Computer Vision/Optical Character Recognition – Offers pattern matching within images and can be used to interpret complicated language-based text recognition
• Natural Language Processing – Translates/extracts human language into computer readable information (think “Hey Siri”) for the purpose of classifying information
• Conversational AI – Uses AI and Natural Language Processing to enable real-time conversations with customers via the use of chatbots
• API End-points – Uses virtual workers to bridge the gap between old systems and new ones by copying and pasting the information across

The Right not to be Subject to Automated Decision-Making Including Profiling

You have the right not to be subject to a decision, which may include a measure, evaluating personal aspects relating to you, which is based solely on automated processing and which can produce significant affects, such as automatic refusal of a claim. Such processing includes ‘profiling’ that consists of any form of automated processing of personal data evaluating the personal aspects relating to you, to analyse or predict aspects concerning your claim, where it produces legal effects or similarly significantly affects you.

Should you wish to question if you have been subjected to automated decision making, including profiling and/or wish to object to such processing and obtain human intervention, please send an email to: dpo@davies-group.com

Data security

Davies Group Limited are committed to ensuring the security of the personal information provided to us and 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. Also, 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.

If at any point you suspect or become aware of a security incident (i.e. your password is stolen, or you receive suspicious communication from someone holding themselves out to be a Davies Group employee or from a dupe website claiming to be affiliated with Davies Group), please let us know by contacting us on dpo@davies-group.com or write to the Data Protection Officer, Davies Group, 3rd and 4th Floors, No.2 Smithfields, Stoke-on-Trent ST1 3DH, UK.

Davies Group are accredited to, and compliant with, the ISO 27001 security standard. This is a leading international standard published by the International Organisation for Standardisation (ISO), developed to help companies handle information security and data protection.

International transfers

We do not knowingly transfer any personal data outside the European Economic Area (EEA), without consent from our data subjects or policy holders. Where data is transferred between the United Kingdom (UK) and the EEA, or from the EEA to the UK, this is done in line with the Standard Contractual Clauses set out by the European Commission to ensure sufficient data protection safeguards for data that is transferred internationally.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at dpo@davies-group.com or write to the Data Protection Officer, Davies Group, 3rd and 4th Floors, No.2 Smithfields, Stoke-on-Trent ST1 3DH, UK

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Subsidiaries

The Davies Group incorporates the following legal entities, all registered in England and Wales unless otherwise stated. Registered office unless otherwise stated: 5^th Floor 20 Gracechurch Street, London, United Kingdom, EC3V 0BG: