Evolve Brokers Limited and its subsidiaries and affiliates, Evolve Brokers LTD, (“Company,” “we,” or “us”) is committed to protecting the privacy of the individuals we encounter in conducting our business. “Personal Information” is information that identifies and relates to you or other individuals (such as your dependents). Our aim is the responsible handling of Personal Information. We respect your privacy and are committed to protecting it through compliance with this Policy.
This Policy describes the types of information we may collect from you or that you may provide when you visit the website evolvebrokers.co.uk (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Last Updated: November 2018
- On this Website, the software applications made available by us for use on or through computers and mobile devices (“Apps”) (collectively, including the Website and the Apps, referred to as the “Evolve Online Services”); and
- Other means (for example, from your application and claim forms, telephone calls, emails and other communications with us, as well as from claim investigators, witnesses or other third parties involved in our business dealings with you).
Who to Contact About Your Personal Information
- If you have any questions about our use of your Personal Information you can email firstname.lastname@example.org or write to:
Evolve Brokers LTD
1 Gracechurch Street, 2nd Floor
London EC3V 0DD
Personal Information That We Collect
Depending on your relationship with us (for example, as a consumer policyholder; insured person benefiting under another policyholder’s policy, or claimant; witness; commercial broker or appointed representative; or other person relating to our business), Personal Information collected about you and your dependents may include:
- General identification and contact information
Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; passwords on our systems; educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.
- Identification numbers issued by government bodies or agencies
Social Security or national insurance number; passport number; tax identification number; military identification number; or driver’s or other license number.
- Financial information and account details
Payment card number; bank account or other financial account number and account details; credit history and credit score; assets; income; and other financial information.
- Medical condition and health status
Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.
- Other sensitive information
In certain cases, we may receive sensitive information about you for example, if you apply for insurance through a third party marketing partner that is a professional, trade, political, religious or community organization. In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).
- Telephone recordings
Recordings of telephone calls to our representatives and call centers.
- Photographs and video recordings
Photographs or video recordings created in connection with our insurance or other business activities, including for claims assessment, processing, settlement, and disputes, or for other relevant purposes as permitted by law.
- Information to investigate or prevent crime, including fraud and money laundering
For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
- Information enabling us to provide products and services
Location and identification of property insured; travel plans; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; and other insurance you hold.
- Information from Other Sources
To improve the quality of our products and services, and to carry out research and analysis, we and our service providers may supplement the Personal Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from our affiliates or business partners.
How We Use Personal Information
We use this Personal Information to:
- Communicate with you and others as part of our business;
- Send you important information regarding changes to our policies, other terms and conditions, our Evolve Online Services and other administrative information;
- Make decisions about whether to provide insurance and assistance services, and other products and services which we offer, and provide such products and services, including claim assessment, processing and settlement; and, where applicable, manage claim disputes;
- Assess your eligibility for payment plans, and process your premium and other payments;
- Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers);
- Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks;
- Identify you to anyone to whom you send messages through any of the Evolve Online Services;
- Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; data analytics; business continuity; and records, document and print management;
- Resolve complaints, and handle requests for data access or correction;
- Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering, sanctions and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence);
- Establish and defend legal rights; protect our operations or those of any of our group companies or business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
International Transfer of Personal Information
- With respect to the Personal Data of EU residents, we participate in the U.S. Department of Commerce’s EU Privacy Shield (“Privacy Shield”). We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. We subject to the Privacy Shield’s Principles all Personal Information received from the EU in reliance on the Privacy Shield. If there is any conflict between this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern in matters regarding EU residents. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.
Evolve will only process Personal Information in ways that are compatible with the purpose that Evolve collected it for, or for purposes the individual later authorizes. Before we use your Personal Information for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Evolve maintains reasonable procedures to help ensure that Personal Information is reliable for its intended use, accurate, complete, and current.
Sharing Personal Information with Third Parties
Evolve may make Personal Information available to:
- Our family of companies
Other Group companies may have access to and use of Personal Information in connection with the conduct of our business where appropriate.
- Other insurance and distribution parties
In the course of marketing and providing insurance and processing claims, Evolve may make Personal Information available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; distributors; affinity marketing partners; and financial institutions, securities firms and other business partners.
- Our service providers
External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers; call center service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; third-party claim administrators; document and records management providers; claim investigators and adjusters; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
- Governmental authorities and third parties involved in court action
Evolve may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies)in response to lawful requests by such public authorities; and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with national security or other law enforcement requirements; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to comply with applicable law, including laws outside your country of residence ; (e) to enforce our terms and conditions; (f) to protect our operations or those of any of our family of companies; (g) to protect our rights, privacy, safety or property, and/or that of our family of companies, you or others; and (h) to allow us to pursue available remedies or limit our damages.
- Other Third Parties
We may share Personal Information with payees; emergency providers (fire, police and medical emergency services); retailers; medical networks, organizations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.
Evolve may disclose your Personal Information as described above, but only for the limited and specified purposes described in this notice, consistent with the consent you have provided. In the event we transfer your Personal Information, we will take appropriate measures to protect your privacy and the Personal Information we transfer. Should we need to transfer your Personal Information for purposes other than as stipulated in this Policy, we will, to the extent permitted by law, obtain assurances from the recipients that they will safeguard your Personal Information in a manner that is consistent with this Policy. In addition, if we learn that an agent is using or disclosing your Personal Information in a manner that is contrary to this Policy, we will take reasonable steps to prevent or stop such use or disclosure. Evolve may be liable for onward transfers of Personal Information to third parties in violation of this Policy and the Privacy Shield.
Evolve will take appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. See contact information below.
When Evolve provides Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information.
If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.
Personal Information of Other Individuals
- You may have the right to access the Personal Information that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Information, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
- You can direct any questions or complaints about the use or disclosure of your Personal Information to us as set out in the ” Who to Contact About Your Personal Information” section above. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Information within 45 days of receiving your complaint.
- With respect to the Personal Information of EU residents, we verify our compliance with the Privacy Shield and the terms of this Policy by conducting a periodic self-assessment. Any complaint or dispute about how we handle EU Personal Information should be directed to the contact information provided above. If we are unable to reach a mutually satisfactory resolution for such complaint or dispute, we have agreed to cooperate with the dispute resolution procedures administered by the European Data Protection Authorities (DPA). We commit to cooperate with EU DPAs and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of any employment relationships. With respect to such EU Personal Information, we are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Under certain limited conditions, by providing notice to us, you may invoke binding arbitration regarding certain residual claims. We participate in the American Arbitration Association dispute resolution program (www.adr.org ).
Use of Services by Minors
- The Evolve Online Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Evolve Online Services.
- This Policy reflects our business practices and is not a contract. However, we are required to and will abide by the terms of this Policy as currently in effect. We may amend this Policy at any time and will notify you of any updates by posting a revised policy on our website. The revised policy will apply to all information collected by us, including previously collected information (for EU residents, this applies to the extent permissible under the Privacy Shield). Your continued use of our website, products or services following any such amendment shall constitute acceptance of the revised policy. You are responsible to regularly review this Policy.