This Statement does not apply to your use of a third party site linked to on this website.
Stubben Edge Group Limited a limited company incorporated in England and Wales with registered number 07227141, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ and its subsidiaries are listed in Schedule 1 (“we”). collects personal information from its clients about their customers to provide insurance intermediary services, loyalty offerings, and IT services. We also collect some personal information directly, for example over our websites and applications.
Stubben Edge Group Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Stubben Edge uses personal information to deliver services to clients, which includes marketing any financial services offerings and/or what we deem marketing of products that we view to be in your legitimate interests. For its own purposes, it also uses personal information to analyse and improve how it delivers those services, to contact representatives of its clients or prospective clients and to market to them.
In the event that we use any of your personal information, you will have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why we use your information.
If you have any questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, or would like to make a complaint about a breach of Data Protection Legislation or this Statement, please contact us on firstname.lastname@example.org. Alternatively, you have the right to contact your local Data Protection Authority.
Do read this Policy with care. It provides important information about how we use personal data and explains your statutory rights. This Policy is not intended to override the terms of any insurance policy or contract you have with us, nor rights you might have available under applicable data protection laws.
Stubben Edge Group Limited is the parent company for Stubben Edge Risk Limited, Lucid Ux Limited, Stubben Edge Wealth Limited, Stubben Edge SA (Pty) Ltd, and Stubben Edge Operations Limited, Limited, Genesis Special Risks Limited, Akoni Hub Limited, Finpoint Limited, and Stubben Edge (Labs) Limited who could be originally responsible for collecting information about you.
- What personal data do we collect:
Prospective Insureds and Insured Persons. In order to underwrite and administer insurance policies, we collect information about the prospective insured, policyholder and related parties. This may include background and contact information on the prospective insured, policyholder or their representative, and matters relevant to the assessment of risk and management of insurance policies. The prospective insured or policyholder may be an individual, company or their representative. The level and type of personal data we collect and use varies depending on the type of policy that is applied for or held and may include information on other individuals who need to be considered as part of the policy. In some instances, it is necessary for us to collect and use Sensitive Personal Data, such as information about past criminal convictions.
We are required to establish a legal exemption to use your Sensitive Personal Data
If you are an insured person, from time to time you may need to provide us with the personal data of third parties, for example an injured third party in relation to a claim under a liability policy. Wherever possible, you should take steps to inform the third party that you need to disclose their details to us, identifying Stubben Edge as your insurer. We will process their personal data in accordance with this Policy.
Claimants. If you are making a claim under a policy, we will collect your basic contact details, together with information about the nature of your claim and any previous claims. If you are an insured person we will need to check details of the policy you are insured under and your claims history. Depending on the nature of your claim, it may be necessary for us to collect and use Sensitive Personal Data, such as details of personal injury you may have suffered during an accident.
Business Partners and Visitors.
If you are a business partner, we will collect your business contact details. We may also collect information about your professional expertise and experience. We may collect your contact details, if you visit our website, register for a newsletter or attend one of our events. If we collect personally identifiable information through our website, we will make it clear when we collect personal information on the basis contained in this notice.
- When do we collect your personal data?
Prospective Insureds and Insured Persons
We will collect information from you directly when you apply for a policy.
Information about you may also be provided to us by an insurance broker, your employer, family member or any other third person who may be applying for a policy which names or benefits you.
We may collect information about you from other sources where we believe this is necessary to manage effective underwriting of the risk associated with a policy and/or helping fight financial crime. These other sources may include public registers and databases managed by credit reference agencies and other reputable organisations
We will collect information from you when you notify us of a claim. You might make a claim to us directly, or through your representative or through your broker or one of our representatives who manage claims on our behalf. We may discuss claims with you on the telephone, in person or via video interviews conducted by us or our third party representatives.
We may also collect information about you if the claim is made by another person who has a close relationship with you or is otherwise linked to the claim – for example if the policyholder is your employer, or if you are the subject of a third party claim.
We may also be provided with information by your solicitors (or acting on behalf of your employer).
We may collect information from other sources where we believe this is necessary to assist in validating claims and/or fighting financial crime. This may include consulting public registers, social media and other online sources, credit reference agencies and other reputable organisations.
Business Partners and Visitors
We will collect information about you if you or your company provides your contact or other information to us in the course of working with us, either directly as a business partner or as a representative of your company.
We may also collect information about you if you attend meetings, events or conferences that we organise, contact us through our website or sign up to one of our newsletters or bulletin services.
We may collect information from other public sources (e.g. your employer’s website) where we believe this is necessary to help manage our relationships with our business partners.
Applicable to all
If you telephone Stubben Edge (for example, when notifying a claim or discussing that claim with us) or if Stubben Edge telephones you (for example, to sell an insurance policy) we may record the telephone call. We use call recordings as an evidence of your agreement to purchase an insurance policy or submit a claim, to help train our staff and to provide an accurate record of the call in case of complaints or queries. We may also analyse call recordings using automated technology in order to detect where there may be customer service failings (and then to resolve these), or to detect potential evidence of fraud.
- What do we use your personal data for?
Prospective Insureds and Insured Persons. If you are a prospective insured or an insured person we will use your personal data to consider an application for an insurance policy, assess and evaluate risk, and subject to applicable terms and conditions, provide you with a policy. The underwriting process may include Profiling. If we have provided you with your policy we will use your personal data to administer your policy, deal with your queries, and manage the renewal process. We will also need to use your personal data for regulatory purposes associated with our legal and regulatory obligations as a provider of insurance.
Claimants. If you are a claimant we will use your personal data to assess the merits of your claim, and potentially to pay out a settlement. We may also need to use your personal data to evaluate the risk of potential fraud, a process which may involve Profiling, which uses automated processes. If you are also an insured person, we will use personal data related to your claim to inform the renewal process and potentially future policy applications.
Business Partners and Visitors. If you are a business partner we will use your personal data to manage our relationship with you, including sending you marketing materials (where we have appropriate permissions) and to invite you to events. Where relevant, we will use your personal data to deliver or request the delivery of services, and to manage and administer our contract with you or with your employer. If you are a visitor, we will use your personal data; typically, to register for certain areas of our website, enquire for further information, distribute requested reference materials, or invite you to one of our events.
Data analytics. We routinely analyse information in our various systems and databases to help improve the way we run our business, to provide a better service and to enhance the accuracy of our risk and other actuarial models. We take steps to protect privacy by aggregating and where appropriate anonymising data fields before allowing information to be available for analysis.
- Protecting your privacy
We will make sure that we only use your personal data for the purposes set out herein, provided you have provided your consent to us using the data in that way
Our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you (e.g. to manage your insurance policy)
Our use of your personal data is necessary to comply with a relevant legal or regulatory obligation that we have (e.g. to comply with FCA/PRA requirements), or
Our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to improve our products, or to carry out analytics across our datasets), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
Before collecting and/or using any Sensitive Personal Data we will establish a lawful exemption which will allow us to use that information. If your Sensitive Personal Data is collected on a form (including on a website) or over the telephone, further information about the exemption may be provided on that form. This exemption will typically be:
your explicit consent (if this is specifically requested from you on a data collection form, in language which references your consent);
the establishment, exercise or defence by us or third parties of legal claims; or
a specific exemption provided under local laws of EU Member States and other countries implementing the GDPR which is relevant to the insurance industry, such as the ‘insurance purposes’ exemption under the UK Data Protection Act 2018.
PLEASE NOTE if you provide your explicit consent to permit us to process your Sensitive Personal Data, you may withdraw your consent to such processing at any time. However, you should be aware that if you choose to do so we may be unable to continue to provide insurance services to you (and where you withdraw consent to an insurer’s or reinsurer’s use it may not be possible for the insurance cover to continue). This may mean that your policy needs to be cancelled. If you choose to withdraw your consent we will tell you more about the possible consequences, including the effects of cancellation, (which may include that you have difficulties finding cover elsewhere), as well as any fees associated with cancellation.
- Who do we share your personal data with?
We work with third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data.
For Prospective Insureds these third parties may include:
Brokers other Insurers and Re-Insurers and TPA’s who work with us to help manage the underwriting process and administer our policies
Service Providers, who help manage our IT and back office systems
Our regulators, which may include the FCA, PRA and ICO, as well as other regulators and law enforcement agencies in the E.U. and around the world
Credit reference agencies and organisations working to prevent fraud in financial services.
If you’ve been introduced to us by another company (e.g. bank, insurer, building society, your employer or their financial adviser), we may share your information with them to enable them to:
- Administer and service your products.
- Carry out market research, statistical analysis and customer profiling.
- Where you have consented, send you marketing information by post, telephone, e-mail and SMS about their products and those of carefully selected third parties.
- Assist you with your application process (aggregator and price comparison websites only).
For Claimants this may include:
Third Party Administrators who work with us to help manage the claims process
Loss Adjusters and Claims Experts who help us assess and manage claims
Service Providers, who help manage our IT and back office systems
Assistance Providers, who can help provide you with assistance in the event of a claim
Solicitors, who may be legal representatives for you, us or a third party claimant
Credit reference agencies and organisations working to prevent fraud in financial services
We may be under legal or regulatory obligations to share your personal data with courts, regulators, law enforcement or in certain cases other insurers. If we were to sell part of our businesses we would need to transfer your personal data to the purchaser of such businesses.
Please see below for relevant definitions: