Our Privacy Notice
Personal Information This privacy notes tells you what to expect when SMI Placings Limited collects personal information about you.
Personal Information denotes:
• Information you provide us with by filling in online forms or online questionnaires via our website
• Information you provide us with by completing a proposal form
• Information that you provide us with over the telephone, via email or face to face
By providing us with information about yourself, you are considered to be a Data Subject.
The Data Protection Principals
As we are responsible for gathering and using your personal information, we have to follow strict rules called the data protection principles. As such, we must make sure that your information is:
√ Used fairly and lawfully in a transparent manner
√ Used for explicit and legitimate grounds only
√ Used in a way that is adequate, relevant and not excessive
√ Accurate and kept up to date
√ Kept for no longer than is absolutely necessary
√ Handled according to your rights
√ Kept safe and secure
√ Not transferred outside the European Economic Area without adequate protection
Who Is Responsible For Your Personal Information
SMI Placings Limited, as the Data Controller determines the purposes for which and the manner in which any personal data is, or is to be, processed.
Data Controllers must ensure that any processing of personal data for which they are responsible complies with the Act.
The person responsible for Data Protection at SMI Placings Limited is Steve Mahmut.
Why We Gather Personal Information About You
We provide a range of insurance products such as property owners insurance, motor fleet insurance, contractors insurance etc. We process data provided by you (the Data Subject) and other sources in order to deliver the appropriate products and services to you.
The reasons for processing your data is mainly to:
√ Provide you with a quotation for insurance
√ Arrange and administer your policy if you buy one through us
√ Arrange premium credit if required √ Inform you about our products and services
√ Help you with any claims that may arise
We do not collect more information than we need to meet our obligations to you and will not retain it for longer than is necessary.
Some of the personal information we ask you to provide may be sensitive (special category) as defined in the legislation. For example you may have to give us information criminal convictions or driving offences. We are allowed by the legislation to collect such information for insurance purposes without specific consent but it will only be used for the purposes set out above.
We will only ever use your personal information for the purpose of progressing your application for insurance, administering your insurance policy, arranging credit, dealing with a claim, or fulfilling our legal or regulatory requirements such as fraud prevention, help preventing financial crime and audit purposes.
Who Do We Share Your Details With and Why
As a necessary part of providing you with the services described above or in our own legitimate interests we may need to disclose your personal data to other third parties.
• Premium finance companies
• Computer / Software Houses
• Insurers • Other Insurance Intermediaries
• Insurance Industry databases
• Government databases
• Credit agencies
• Regulatory authorities
If you provide us with information about another person, in doing so, you confirm that they have given you permission to provide it to us and that we may use their personal data in the same way as your own as set out in this Privacy Notice.
Legal Basis For Processing Your Personal Information
We are required to have a lawful basis in order to process your personal data and the relevant bases which apply:
Purpose of Processing Lawful Basis Providing quotations, arranging and administering insurance policies Necessary for the performance of an insurance contract Assisting you in the event of a claim Necessary for the performance of an insurance contract Arranging Premium Credit / consumer credit Necessary for the performance of a consumer credit contract Provision of information on products and services Our legitimate interests or your explicit consent To notify you of changes to our service Our legal and regulatory obligations To prevent and detect fraud, money laundering and other financial crimes Our legal and regulatory obligations To meet general legal or regulatory obligations Our legal and regulatory obligations
The type of insurance we arrange for you dictates the amount of time we retain your personal information for. For the majority of insurance products, we retain records for a period of 7 years after your insurance contract with us expires. For insurance which includes Employers Liability then we retain records indefinitely and for other liability related insurance products, we retain records for a period of 12 years after your insurance contract with us expires.
We are committed to protecting the security and privacy of all personal information which we obtain and hold about you.
We employ appropriate technical security measures to protect your personal information and ensure that it is not accessed by unauthorised persons. Information is stored on secure computers, in a locked office, and information is encrypted wherever possible.
We use a third party service, wix.com Ltd to help maintain the security and performance of our website. To deliver this service it processes the IP addresses of visitors to our website.
We use SADS IT Limited to assist with our email security.
Cookies In General Cookies
are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
The cookie is sent back and forth between a web browser and the server it accesses. The information a cookie contains and its purpose is determined by the website operator and can be used by the web server every time you visit that site.
Cookies are used to save time and make visiting web sites more efficient, to record site usage and remember information input on forms and pass information from page to page during a single user's website session.
They can be used for many different reasons - from remembering login information and what is in your online shopping basket and in respect of online adverts so you see more adverts suited to what you want.
Cookies At SMI Placings Limited
• To provide a great experience for visitors and customers
• To monitor and analyze the performance, operation and effectiveness of Wix's platform
• To ensure their platform is secure and safe to use
The information that is collected from cookies is anonymous and does not identify people or collect personal data about website visits.
How Can You Manage Your Cookies?
You can manage how your computer/internet device manages cookies through your browser settings.
Most browsers can be altered to prevent your computer from accepting cookies. This may result in some of the features of this site and other sites not working properly and may restrict your user experience.
How To Manage Your Cookie Settings In:
There is lots of guidance available explaining what cookies are and what they can do.
More Information about Cookies
More information to help you find out more about cookies can be found on the following links: -
Conditions of Use
Acceptance of these cookies is a condition of using the SMI Placings Limited website and if these cookies are restricted or refused in any way we can offer no guarantee that the site will function properly for you.
Where Your Information Is Stored
Wix.com Ltd use servers located in the EU, the US and worldwide.
Wix.com is certified under the EU-US Privacy Shield Framework and the Swiss-US privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, and therefore adheres to the Privacy Shield Principles
If You Send Us An Email
Any email you send to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
If You Make A Complaint to Us
If we receive a complaint, we make up a file containing the details of the complaint. The file is likely to contain the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to investigate and process the complaint.
We usually have to disclose the complainant’s identity to whomever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute.
We also usually have to disclose details of the complaint to our professional Indemnity Insurance Broker and Insurer.
We may also be required to provide a copy of the file to the Financial Ombudsman Service should an adjudicator be required to consider the complaint.
We are required to disclose high-level analytics to the Financial Conduct Authority (FCA) concerning the number and nature of any complaints we receive. This data does not include names or details that identify the specific data subject.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for 3 years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Use of Data Processors
Data processors are third parties who provide elements of our service for us. We use Talisman as our software provider and therefore they would be classed as a Data Processor. We have a contract in place with them. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Under the Data Protection Act 1998, you have rights as an individual which you can exercise in relation to the information we hold about you. From 25th May 2018, the General Data Protection Regulations (GDPR) come into force.
Please ask us for an explanation of each should you wish to have more information:
√ The right to be informed
√ The right of access
√ The right to rectification
√ The right to erasure
√ The right to restrict processing
√ The right to portability
√ The right to object
√ Rights to automated decision and profiling
Your Right To Access
You have the right to access any information we hold about you, and the right to know why that data is being processed, how long it's stored for, and who has had or has access to it.
You will not be charged for us supplying you with this information however we do reserve the right to apply a reasonable fee where requests are deemed excessive.
We will respond to any such request within the maximum time frame allowed of one month.
How To Contact Us
For further information on how your information is used, how we maintain the security of your information and your rights to access the information we hold on you or if you would like to make a complaint, you can write to us, email us, or call us as follows:
Steve Mahmut SMI Placings
Ltd 9 Regent Gate 83
High Street Waltham Cross Hertfordshire
Tel: 01992 787333
If You Have A Complaint
If you have any concerns about your rights and our practices in relation to data protection, please contact us directly using the details provided above. We will aim to respond to your concerns and clarify how we have processed your information and with whom. We will also endeavour to put right anything that's gone wrong.
If you are still dissatisfied after contacting us, you may report your concern to the Information Commissioner’s Office by contacting them as follows:
Information Commissioner's Office
Tel: 0303 123 1113
Version 2 – September 2019