Data Privacy Policy
Background
Eleos Life Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://www.eleos.co.uk (“Our Site”) 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.
Please read this Data Privacy Policy carefully and ensure that you understand it. Your acceptance of this Data Privacy Policy is requested upon first use of Our Site.
1. Definitions and Interpretation
1.1 In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. Information About U
Our Site is owned and operated by Eleos Life Limited, a limited company registered in England under company number 14010855.
Registered address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
3. What Does This Policy Cover
4. What Is Personal Data
5. What Are My Rights
- a) The right to be informed. You have the right to be informed about our collection and use of your personal data. This Data Privacy Policy 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 15.
- b) The right to access your personal data. You have the right to access the personal data we hold about you. Part 13 will tell you how to do this.
- c) The right to have your personal data rectified. If any of your personal data held by us is inaccurate or incomplete, you are entitled to it being rectified. Please contact us using the details in Part 15 to find out more.
- d) The right to be forgotten. This means that you have 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 15 to find out more.
- e) The right to restrict. In other words, you have the right to prevent the processing of your personal data.
- f) The right to object. You are entitled to object to us using your personal data for a particular purpose or purposes.
- g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- h) The right to data portability. This means that, if you have provided personal data to us directly, 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.
- i) Rights relating to automated decision-making and profiling. We make automated decisions about you based on your information and instructions given to us by the Insurer. These decisions can include whether or not you are eligible for one of our plans.
- We may refuse applications where the applicant’s risk profile is too high. This is necessary to keep the price fair for everyone. In all circumstances, the decision to reject your application is made automatically, based on certain checks and calculations during the application process
- 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 15.
- 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. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How
Depending upon your use of Our Site, we may 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. Please also see Part 14 for more information about Our use of Cookies and similar technologies and Our Cookie Policy. We do not collect any personal data relating to children or data relating to criminal convictions and/or offences.
Data Which You Submit Through Our Site
- Identity Information such as name, title, birthday and gender.
- Contact information such as telephone number, mobile number, address and email address
- Employment information such as employment type, job title.
- Payment information including such as bank details.
- Special categories of data such as Health details
Data We Collect When You Visit Our Site
- Technical information such as IP address, browser details, OS details.
7. How Do You Use My Personal Data?
For the Performance of a Contract
- Occupation
- Income
- Date of Birth or Age
- Contact details such as your name, address, email and telephone number
- Bank account details
- Date of birth or age
- Gender
- Residency status
- Tax-payer status
- Health details such as medical history
- Occupation, employment or self-employment details, for example, if you work full or part-time, and, where relevant income, financial and tax details
- Health details such as medical history
- Occupation, employment or self-employment details, for example, if you work full or part-time, and, where relevant income, financial and tax details
- Name
- DOB or Age
- Address
For Legitimate Commercial Interests
- Name
- Email address
- Phone number
- Name
- Email address
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We use the following automated systems for carrying out certain kinds of decision-making and/or profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) 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 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) 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.
8. How Long Will You Keep My Personal Data
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
The Type of Data We Collect
- Identity Information such as name, title, birthday and gender.
- Contact information such as telephone number, mobile number and email address.
- Employment information such as employment type, job title.
- Payment information such as bank account numbers
- Special categories of data such as Health details
How Long We Keep Your Data
- Until the completion of the permitted purpose or as required, if longer, by the Financial Conduct Authority regulations
9. How and Where Do You Store or Transfer My PersonalData?
We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 15 for further information about the particular data protection safeguards 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;
10. Do You Share My Personal Data?
We do not sell, trade or otherwise transfer to third parties your personal data. This does not include trusted third parties who assist us in operating our Site, conducting our business or providing the Services to you, so long as those third parties keep your personal data confidential.
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 Data 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 any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data 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 9.
11. How Can I Control My Personal Data?
11.1 These Site Usage Terms, and the relationship between you and Us (whether contractual or otherwise) shall be governed by, and construed in accordance with the law of England & Wales.
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access to Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict Our use of Cookies. For more information, see Part 14 and Our Cookie Policy.
13. How Can I Access My Personal Data?
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 15. 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 28 days and, in any case, not more than 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.
14. How Do You Use Cookies
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and/or services. For more details, please refer to Our Cookie Policy
15. How Do I Contact You?
16. Changes to this Data Privacy Polic
We may change this Data Privacy Policy 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 immediately posted on Our Site and you will be deemed to have accepted the terms of the Data Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Data Privacy Policy was last updated on 27 July 2023.