Call Assist Privacy Policy

Introduction

This Privacy Policy explains in detail how Call Assist Ltd (“We/Us/Our”) collect, use, share and protect your personal data when you interact with Us. It will also provide you with a better understanding of your rights relating to your personal data and how you can exercise those rights.

We encourage you to take the time to carefully read the sections below. We would also ask that you share this Privacy Policy with anyone whose personal data you intend to share with Us (such as other named drivers of your vehicle).

Updating this Privacy Policy

We reserve the right to amend or update this Privacy Policy at any time and in response to changes in the Data Protection legislation. We will notify you of any changes We consider to be significant, but it is important that you come back from time to time to check for any updates and to ensure that you are happy with them.

Who We are?

We are Call Assist Ltd, Axis Court North Station Road, Colchester, Essex, CO1 1UX (Registered in England and Wales, Registered Number: 3668383). Authorised and regulated by the Financial Conduct Authority (Firm Reference Number: 304838).

For the purpose of the Data Protection legislation, We are the Data Controller of your personal data. This means that We are responsible for deciding how We use your personal data.

Data Protection Officer (“DPO”)

We have a dedicated Data Protection Officer. Should you wish to exercise any of your rights under the Data Protection legislation, or have any questions relating to this Privacy Policy, please direct your enquiry to the Data Protection Officer, Call Assist Ltd, Axis Court, North Station Road, Colchester, Essex CO1 1UX or email: DPO@call-assist.co.uk.

Personal data

Personal data is information about you from which you can be identified. Dependent on which service you receive from Us, We will process different types of personal data about you. We will not process any personal data about you that We do not actually need in order to provide Our services to you.

What personal data do we collect?

The types of personal data We collect include:

• personal details, such as title and your full name;
• contact details, such as your email address and telephone number;
• date of birth;
• home address;
• vehicle information, such as vehicle registration, make and model, reported faults;
• identification documentation, such as your UK driver’s licence, Passport, EU Identity Card, Council Tax Bill, Credit Card Statement, Pension Book and Bank Account Statement;
• credit/debit card details, such as the 16 digit card number, name stated on the card, expiry date, and CV2 number. We only provide the mechanism which collects this information, but it is never transmitted through or stored within Our systems;
• details of beneficiaries, such as named drivers;
• special categories of data, such as details regarding your health (medical conditions, disabilities) limited to those that might affect the provision of Our services to you;
• records of your communication with Us, such as call recordings, emails, text messages, survey comments, complaints regarding Our products or services, made in any form, including complaints made orally, by email, letter and/or by online contact form submissions;
• information relating to contests or any promotions entered;
• marketing communication, such as your response to marketing from Us or through Our third parties;
• policy information, such as policy start date, any callouts and/or claims made;
• telemetry information, such as your mobile phone location data and IP address (which is a unique number identifying your computer), all web pages associated with Call Assist Ltd that are viewed, server requests, details of the browser (including browser type, timings, connections, updates and exceptions), and details of the device you are connected with;
• fraud and theft information, such as any suspected or actual instances of fraud or theft;
• Information We obtain from third parties, such as third party databases available to the insurance industry and firms, loss adjustors and/or suppliers appointed in the process of handling a claim;
• cookies, for details on how we collect cookies please view our Cookies Policy.

What are Our legal grounds and purposes for collecting your personal data?

The legal basis for processing your personal data can differ depending on the personal data that We collect.

For some of the personal data, the legal basis will be ‘contractual obligation’. Without collecting certain information from you, the data subject, it will not be possible for Us to provide you with Our contracted services.

In order to fulfil Our statutory and regulatory obligations, We may need to process and hold certain personal data about you. For example, We are legally obliged to keep records for the purposes of inspection by HMRC and/or FCA.

We have your consent or explicit consent:

Further personal data, for the purposes of marketing for example, will not be processed without your explicit, informed consent. Where We seek to obtain your consent, We will make this clear to you as well as informing you about how you can withdraw that consent should you change your mind at any time. If We do not have your consent, we will not:

• send you direct marketing communications to keep you informed of Our products and services, including but not limited to breakdown cover (e.g. other automotive or financial products, or other carefully selected offers which We believe may interest you);
• process special categories of your personal data, such as medical conditions or disabilities.

It is in Our legitimate interests to do so, such as:

• recording and monitoring calls for training purposes, to improve the quality of Our service, to help Us deal with queries or complaints from you.

Where We deem ‘legitimate interest’ to be the correct legal basis, We shall ensure that We balance your interests with those of Call Assist Ltd at all times.

Because We have a justifiable reason, such as:

• keeping records about you and Our correspondence with you. This is so that We can appropriately and effectively manage Our relationship with you. We may also have to keep such records to satisfy any legal and regulatory obligations;
• preventing and detecting fraud, financial crime and money-laundering.

Disclosing and sharing your personal data

We will only disclose/share your personal data or your policy in the following circumstances:

• it is with companies within the Call Assist Group (for the purposes of this Privacy Policy, “Call Assist Group” means Call Assist Ltd and any company or entity which Call Assist Ltd own more than 15% of the issued share capital. Companies in the Call Assist Group shall include, without limitation, Call Assist Ltd, and any other company that is incorporated within the Call Assist Group at any time in the future);
• in the event that We undergo re-organisation or are sold to a third party, in which case you agree that any personal data We hold about you will be transferred to that re-organised entity or third party;
• if you have given Us consent to do so;
• it is with regulatory bodies, including but not limited to the Financial Conduct Authority (“FCA”), Isle of Man Financial Services Authority (“FSA”) and the Financial Services Commission (“FSC”);
• it is with fraud prevention and credit reference agencies;
• it is required by law;
• in case you make a complaint to Us about the service We have provided, We may be obliged to forward details about your complaint, including your personal data, to the Financial Ombudsman Service (“FOS”);
• it is being provided to Recovery Operators or other suppliers as required to fulfil Our contractual and legal obligations, and in which case your personal data will be limited to the minimum ordinarily required for service provision: additionally, these service providers will only be able to use your personal data to provide the specific services.

In the unfortunate event that you have to make a claim, then We will need to disclose your personal data to any other party involved in that claim. This will usually include:

• third parties involved with the claim, their insurer, solicitor or representative;
• medical team, the police or other investigators.

International personal data sharing and transfers

It may be necessary to transfer your personal data to other Group companies or service providers located outside of the European Economic Area (EEA). We will not transfer your data outside the EEA unless it is to a country which is considered to have equivalent Data Protection laws or We have taken all reasonable steps to ensure the firm has suitable standards in place to protect your personal data.

In the unfortunate event that you have broken down outside the EEA and make a claim, then We will need to disclose your personal data to either:

• the IMA Group, which is Our business partner that is contracted to handle claims on Our behalf outside of the UK. All details for assistance required outside of the EEA will be dealt with through them. IMA will select a local Recovery Operator in the country in which you have broken down and will send required job details to the Recovery Operator via IMA Net. The personal data passed is limited to your: full name, contact number and location of the breakdown.

  Or as of February 2019

• Opteven Services S.A, which is our business partner that is contracted to handle claims on our behalf outside of the UK. All details for assistance required outside of the EEA will be dealt with through them. Opteven will select a local Recovery Operator in the country in which you have broken down and will send required job details to the Recovery Operator. The data passed is limited to your: full name, contact number and location of the breakdown.

Your rights

Under the Data Protection legislation, you have a number of rights relating to the personal data We hold about you. This includes the right to:

• ask for a free copy of any personal data We hold about you;
• ask for correction of any inaccurate personal data held about you;
• object to the use of your personal data for direct marketing;
• withdraw any permission you have previously given to Us to process your personal data except where this is critical to Us fulfilling Our contractual and legal obligations;
• ask for your personal data to be deleted from Our system/database. Please note that there are times when We will not be able to delete your personal data. This may be as a result of Us fulfilling Our legal and regulatory obligations, or where there is a minimum statutory period of time for which We have to keep your personal data. If We are unable to fulfil a request, We will always let you know Our reasons;
• not to be subject to any automated decision making (without human involvement) where that decision produces a legal or significant effect on you. This means you can ask that We involve one of Our members of staff in the decision-making process;
• obtain, move, copy or transfer your personal data in a format which enables you to transfer that personal data to another organisation. You may ask to have your personal data transferred by Us directly to the other organisation, if this is technically feasible;
• request that We suspend Our processing of your personal data. Where We suspend Our processing of your personal data, We will still be permitted to store your personal data, but any other processing of this personal data will require your consent, subject to certain exemptions (for example, processing is required by law or to prevent crime);
• complain to the Information Commissioner’s Office if you are not satisfied with Our use of your personal data (https://ico.org.uk).

Should you wish to exercise any of your rights under the Data Protection legislation, please direct your enquiry to the Data Protection Officer, Call Assist Ltd, Axis Court, North Station Road, Colchester, Essex CO1 1UX; email DPO@call-assist.co.uk.

Data Security

Your personal data is considered to be an important asset to Us, and as such, We make reasonable effort to ensure the necessary measures are in place to prevent unauthorised or inappropriate access, use, modification, disclosure or destruction.

Measures We take to keep your personal data secure include, but are not limited to:

• making regular backups of files;
• protecting file servers and workstations with virus scanning software;
• using a system of passwords so that access to personal data is restricted;
• allowing only authorised staff into certain computer areas;
• using data encryption techniques to code data when in transit;
• ensuring that staff are only given sufficient rights to any systems to enable them to perform their job function.

Retaining your data

We retain your personal data in order to provide you with Our range of products and services to you and/ or to fulfil Our legal and regulatory obligations. If you decide that you no longer wish to use Our products and services, We will retain your personal data in line with Our Retention Policy and/or Our legal and regulatory requirements.

Our Retention Policy is available upon request by contacting: DPO@call-assist.co.uk.

Links to Other Website

In this website certain links, including hypertext links, will lead you to website or pages that are not under Our control. These links are provided for your information and convenience and the inclusion of any link does not imply endorsement by Us in any way of the site to which a particular link leads. We accept no responsibility or liability for the content of other websites. If you are redirected to another website via Our website, you will need to contact that organisation separately to remove your details from their records. No one may link into this site without prior written consent.