Welcome to the i-Wonder Aggregator Services Limited privacy notice.
i-Wonder Aggregator Services Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
i-Wonder Aggregator Services Limited is the controller and responsible for your personal data (collectively referred to as “i-Wonder”, “we”, “us” or “our” in this privacy notice).
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 (detailed below), please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: i-Wonder Aggregator Services Limited
Email address: firstname.lastname@example.org
Postal address: Data Privacy Manager, 3 Warren Farm Barns, Micheldever Station, Winchester, SO21 3FL.
Telephone number: 02380 175134
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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
Our website may include links to third-party websites, plug-ins and applications by means of hyperlink, text or image. 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.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
When you provide information to us it is your responsibility to check that all information you provide is correct, complete and not misleading.
We may collect, use, store and transfer different kinds of personal data about you via our websites, mobile applications or other similar devices which we have grouped together follows:
- • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, driving licence number and vehicle data.
- • Contact Data address, email address and telephone numbers.
- • Transaction Data includes information about whether previous insurance services you applied for were accepted or declined, and your driving history (claims, fault or non-fault).
- • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- • Usage Data includes information about how you use our website and services.
- • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
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 Usage 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.
We do collect Special Categories of Data about you but only in relation to criminal convictions and driving offences (for example, speeding convictions), accident claims and health data where relevant. By completing the form on our website you confirm your explicit consent to the processing of this information for the purpose of enabling us to inform panel insurers for them to provide insurance quotes.
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 (for example, to provide you with goods or services). 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.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:
- use our services;
- create an account on our website;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- (a) analytics providers such as Google based outside the EU;
- (b) Contact, and Transaction Data from providers of technical, payment and delivery services such as the Driver and Vehicle Licensing Agency to enable us to obtain exact vehicle details, based inside the EU.
- • Identity and Contact Data from publicly availably sources such as the Royal Mail, based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
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:
- • Where we need to perform the contract we are about to enter into or have entered into with you.
- • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- • Where we need to comply with a legal or regulatory obligation.
5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
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 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.
|What we use your data for
||Type of data
||Lawful basis for processing including basis of legitimate interest
To register you as a new user of our service and to send you service updates.
This is necessary so that we can provide our services to you in accordance with our website terms and conditions
To process the data you provide approved insurance providers in order to obtain their quotes and for contact purposes (to discuss your quotation), further to your enquiry.
Except for auto-complete services (see next row) we do not pass this information on to any other third parties outside of www.Confused.com.
(d) Marketing and Communications
This is necessary so that we can provide our services to you in accordance with our website terms and conditions when requesting an insurance quote to deliver it to our panel of insurance providers.
If we are involved in processing special category data, we will do so in accordance with the law.
We do not ask for your consent to enable insurance providers on our panel to send you marketing materials as we do not permit them to do this.
We only send your data to those on the panel to enable them to provide a quote. We do not permit these organisations to use your data for any other purpose.
When the top 2 insurance quotes providers contact you, or invite you to visit their website, it is up to you to ensure you take control of any rights these companies might like to obtain to send you direct marketing about their goods and services and those of any of their third parties. Under the new GDPR law they must ask you for your consent to do this and they must obtain a positive indication of your acceptance, so this means they are not allowed to pre-tick a box that says they will send you direct marketing. Nothing should stop you getting or proceeding with your insurance so you are under no obligation to accept their direct marketing.
To share data you provide to us with recognised and approved third party organisations for the sole purpose of auto populating the form you are completing on our site (for example with your complete home address) or to refine the information you provide (for example about the make and model of your car)
Necessary for our legitimate interests to ensure we obtain the most accurate information possible in order to ensure the best possible service can be provided to you, giving you the most relevant options for quoting insurance providers, and speeding up the process of completing the form for you.
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for both of our legitimate interests (to keep our records updated and to study how customers use our products/services to refine and improve our services to you)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To detect and prevent fraud or other types of online crime.
(a) Necessary for both of our legitimate interests (for running our business, provision of administration and IT services, network security, to reduce or prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) By reducing fraud, we are able to benefit our customers by bringing down the cost of insurance premiums.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you based upon the data we have informing us about previous services you have bought.
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/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, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To comply with any law enforcement related requests or to comply with regulatory requirements.
To make suggestions and recommendations to you about any services we provide that we consider may be of interest to you, and to send you news, promotions and marketing information from i-Wonder Aggregator Services Limited (only).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
• PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile 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 (we call this marketing).
You will only receive marketing communications from us if you have opted in to receive marketing information from us or, being an existing account holder who has used our service before, if you have not opted out of receiving such information.
• THIRD-PARTY MARKETING
We do not currently share your data with any third-party company outside of www.Confused.com for marketing purposes and would require your express opt-in consent should we decide to do so in the future.
• OPTING OUT
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.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of obtaining a quote or purchasing a product.
Cookies are not viruses and will not harm your computer, and we do not use them to store personally identifiable information such as credit card details. We do, however, use encrypted information gathered from them to help improve your experience of our website. For example, they can help us to identify and resolve errors and other problems that affect your experience of using our site. For further information about the cookies we use, please see our Cookies Policy.
Our website may use SessionCam for analysis. SessionCam is a product that has been developed by SessionCam LTD. SessionCam may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. The information collected does not include bank details or any sensitive personal data. Data collected by SessionCam from www.Confused.com website is for i-Wonder Aggregator Services Limited internal use only. The information collected is used to improve our website usability and is stored and used for aggregated and statistical reporting.
If you prefer not to allow your data to be recorded by SessionCam you can use the link below which will take you to a page on the SessionCam website where you can enable the masking of all data:
• 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 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.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
- • Internal Third Parties as set out in the Glossary.
- • External Third Parties as set out in the Glossary.
- • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
8. DATA SECURITY
i-Wonder takes the security of your data very seriously as do our insurance partners, who all have their own security policies.
• Security measures and staff confidentiality
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 (Industry-standard secure sockets layer (SSL) 256-bit encryption technology to ensure that all your personal and financial information is encrypted before transmission). In addition, 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.
• Padlock Icon
When the closed padlock icon appears at the bottom right or top of your browser, you are in a secure area of our website. Our powerful security measures are intended to safeguard your privacy from unauthorised access or improper use and we will continue to update our security measures as new security technology becomes available.
• Data breach procedure
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.
• No liability for third party security
i-Wonder is not and cannot be responsible for the privacy policies and practices of our partners and their websites or other services that you may use but that we do not control. We request (but cannot insist) that our partners show the same commitment to security and also offer SSL encryption throughout their quotation process wherever possible, but if you access a third-party website using a link from an i-Wonder website we recommend that you check their security policy during the visit.
• Password protection
There are several ways that we can help you if you forget your password. The most straightforward is to simply click the 'forgotten password?' link that appears just below the box into which you would type your password, complete the details and we will email your password to the address you have us previously. If you have changed your email address, you will need to contact us and we will guide you through the rest of the process.
Don't forget that internet based communications are not secure unless they are encrypted, which means you shouldn't put sensitive information in an unsecured email or webmail (most email and webmail services are not encrypted). The nature of the internet means any communications may route through many countries.
We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
9. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please Contact us.
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 may 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 may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES
Other companies in the i-Wonder group acting as joint controllers or processors and who are based in the UK and provide similar services or group administration services.
EXTERNAL THIRD PARTIES
- • Insurance Fraud Bureau based in the UK for fraud intelligence services.
- • Service providers acting as processors based in the UK who provide IT and system administration services.
- • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- • HM Revenue & Customs, regulators and other authorities acting as joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- • The ICO, CMA, FCA and the DVLA.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 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.