MANAGEMY LIMITED
PRIVACY NOTICE FOR
DEMONSTRATION APP & PORTAL

BACKGROUND:

ManageMy Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value your privacy and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

ManageMy Limited is a private limited company registered in England under company number 10387815. We provide software development and application solutions to business partners and clients in the insurance sector.

Our registered address is Munro House, Portsmouth Road, Cobham, Surrey, KT11 1PP.

Our main trading address is Clarendon House, 1st Floor Rear Suite, Victoria Avenue, Harrogate, HG1 1JD.

VAT number: 306458994

We have appointed a Lead Controller who is responsible for our compliance with data protection laws. The Lead Controller’s contact details are:

Name: Gino Maccio
Email address: dataqueries@managemy.com
Telephone number: 0207 164 6231
Postal address: Clarendon House, 1st Floor Rear Suite, Victoria Avenue, Harrogate, HG1 1JD.

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
  • The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for a particular purpose or purposes.
  • The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data for a specific purpose, you are free to withdraw that consent at any time.
  • The right to data portability. This means that, if you have provided personal data to us directly, and we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights related to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113

We collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. We also collect some ‘special category’ data which is also set out in the table below. We do not collect any personal data relating to children or data relating to criminal convictions and/or offences.

Data Collected How We Collect the Data
Identity information including title, name, date of birth. You provide this information to us when you create your profile and register for our demo application.
Contact information including address, email address, telephone number. You provide this information to us when you create your profile and register for our demo application.
Claims information including documents and images that describe and evidence the cause and extent of damage. You provide this information to us when you make a claim (for home insurance) on our demo application.
Health and lifestyle information including occupation, height, weight, smoker status, medical history. This is known as ‘special category’ data. You provide this information to us when you add life or travel insurance on our demo application.
Payment information including bank account name, number, sort code, credit card and CVV number, expiry date details. You provide this information to us when you add life or travel insurance on our demo application.
Photographs of self (‘selfies’) You provide this information to us when you use our facial analytics service.

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:

What We Do What Data We Use Our Lawful Basis
Creating your individual profile and assigning your demo insurance policy details.

Giving you access to your demo insurance policy details.Enabling you to update or amend your details.

Communicating any changes to your insurance policy arrangements.

Soliciting and acting upon your feedback in order to improve the design and functionality of our products and services.

Demonstrating how marketing messages are communicated.

Identity and contact information Legitimate interest.
Demonstrating the assessment and processing of insurance claims for our demo products. Claims information. Legitimate interest.
Demonstrating the calculation of a demo quote for life and travel insurance, the confirmation of cover and acceptance, and, the setting up of demo policy payment details. Health and lifestyle information, payment information. Legitimate interest.
Demonstrating the facial analytics service we offer. Photographs of self. Legitimate interest.

We only use your personal data for the purposes for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purposes and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purposes for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. Your personal data will therefore be kept for the following periods:

Type of Data How Long We Keep It
Identity information including title, name, date of birth. We will keep this until you ask us to remove it or until we no longer have an active business relationship with you.
Contact information including address, email address, telephone number.
Claims information including documents and images that describe and evidence the cause and extent of damage.
Health and lifestyle information including occupation, height, weight, smoker status, medical history. This is known as ‘special category’ data.
Payment information including bank account name, number, sort code, credit card and CVV number, expiry date details.
Photographs of self (‘selfies’)

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
AND
We share your data with external third parties, as described below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:
We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
AND
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
OR
We transfer your data to a third party based in the USA that is protected by the EU-US Privacy Shield. This requires that third party to provide data protection to standards and similar levels to those in Europe. More information is available from the European Commission.

Please contact us using the details below in Part 11 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

We will not share any of your personal data with any third parties for any purposes subject to the following exceptions.

We may share your personal data with other companies in our group for company administration and operational purposes. This includes our holding company and its subsidiaries.

We may sometimes contract with the following third parties to supply products or services.

Recipient Activity Carried Out Sector Location
Twilio & SendGrid Provide secure API communication services Technology USA
Livegenic Provide bespoke mobile technology and tools that are integrated into our products/services workflow Technology USA
LSI (distribution partner) Sourcing of potential clients to market our products/services Marketing USA
IDS Code writing and creation of application platform to meet specification Technical Belarus
Lapetus Solutions Inc Facial recognition technology Technology USA

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that it is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Gino Maccio):

Email address: dataqueries@managemy.com
Telephone number: 0207 164 6231
Postal Address: Clarendon House, 1st Floor Rear Suite, Victoria Avenue, Harrogate, HG1 1JD.


Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website. This Privacy Notice was last updated on 13 September 2019.