Privacy Policy and Cookie Information

This Privacy Policy (‘Policy’) applies to www.bpl-insurance.com and describes how BPL collects, uses and protects personal information collected through this website which is hosted in the U.K. or otherwise may be collected through our web-based client portal, BPL Sphere. This Policy also describes how personal information may be used for marketing communications where such personal information has been obtained other than through this website because you or your employer are a client, prospective client or underwriter with whom BPL has a business relationship.

This Policy may be revised from time to time to reflect changes in the law or our operations.

The term ‘BPL’ or ‘us’ or ‘we’ refers to the owner and data controller of the website whose registered office is Berry Palmer & Lyle Limited, 52 Lime Street, London, EC3M 7AF. Our company registration number is 01661686, registered in England and Wales. The term ‘you’ refers to the user or viewer of our website, and/or where you have been granted access to BPL Sphere.

By accessing, browsing or otherwise using this website and/or BPL Sphere, you confirm that you agree to this Policy. If you do not agree to this Policy in its entirety, you must not use this website and/or BPL Sphere. If you or your employer are a client of BPL, you should also consult the privacy statement in our Terms of Business, which covers our use of personal data as a business generally.

Information we may collect from you

The information we may collect from you through this website and/or BPL Sphere includes:

• any information you may voluntarily submit to us by completing the ‘Make an Enquiry’ form on the website or emailing us at one of the addresses provided on the Contact page; and
• details of your visits to, and usage of, our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed.

The information gathered by BPL from this website and/or BPL Sphere falls into two categories:

• information voluntarily supplied by users through the completion and submission of an Enquiry Form and/or information provided by your company in order to access BPL Sphere; and
• tracking information gathered as users navigate through our website, obtained from ‘cookies’ and other similar tools deployed on our website and BPL Sphere (for further information regarding cookies used on our websites, please see below).

In addition, if you or your employer are a client, prospective client or underwriter with whom BPL has a business relationship, we may have obtained personal information about you which will not have been gathered via this website or BPL Sphere and which we may use for marketing purposes, as detailed in the section below. Please also refer to the privacy statement in our Terms of Business.

Your personal information is kept private and stored securely until a time when it is no longer required for the purpose for which it was obtained and there is no further basis for retaining the data, in accordance with our internal data retention policy.

What we may do with your personal information

The information we hold and process about you will be used by BPL and/or its affiliates to correspond with you, respond to your queries and otherwise provide services to you. The details which you provide may also be used in order to help us administer the website and/or BPL Sphere, to update our records and/or for marketing purposes. Please advise us if you do not wish your information to be used in this manner.

You will be offered choices regarding the use of your data for marketing purposes at the point at which you submit personal data to us by completing the ‘Make an Enquiry’ via the website, and with each marketing communication you will be given the opportunity to unsubscribe from further communications. You also have the right to ensure your data is not used for marketing purposes at any point, simply by sending an e-mail to [email protected].

BPL does not sell, rent, loan, trade or lease any personal information recorded on, or obtained via, this website.

BPL will only collect, use, or disclose personal information that is necessary for the purposes described above, or as permitted by law. We will collect personal information by fair and lawful means. We will retain personal information as long as necessary in accordance with the purposes described above and our internal data retention policy. However, some personal information may be retained for longer periods as required by law, contract, or auditing requirements.

Legal grounds for processing personal data

Under the UK General Data Protection Regulation (UK GDPR), we will process personal data disclosed by you, or collected from you, via this website on the basis that it is in our legitimate interests to do so, and that such interests are not overridden by the interests or fundamental rights or freedoms of the relevant data subjects. Such legitimate interests include our ability to provide insurance intermediary services to you, should you request this, and our ability to monitor traffic and usage of our website and/or BPL Sphere in order to maintain sufficient security procedures. We may also process certain personal data in order to comply with legal obligations to which we are subject.

Disclosure of your information

We will not disclose any personal information about you which has been obtained from this website or otherwise obtained due to our on-going business relationship with you to any third parties, except as stated in this Policy, as otherwise permitted by law, or authorised by you.

We may disclose your personal information to any company affiliated or associated with BPL for the uses and purposes set out above.

We may disclose your personal information to independent third parties, including the following:

• Our third party service providers– for example, platform and software providers
• Third parties related to the performance of our services for you– for example, if you are a client or prospective client, insurers at Lloyd’s or member companies of the International Underwriting Association of London, or other insurers underwriting credit and political risk insurance both in the UK and overseas
• Other third parties for legal reasons– for example, if we are obliged to disclose your personal information under applicable law or regulation, in order to enforce or apply our website Terms of Use and/or Terms of Business, to protect or defend the rights of BPL, our clients, or other parties.

If we transfer your personal information outside the UK or European Economic Area, to BPL affiliates or to third parties such as insurers overseas, we will ensure that there is a valid transfer mechanism in place under UK GDPR. For transfers to affiliates, this is achieved through a data sharing agreement and for transfers to insurers, we will implement the approved Model Clauses where necessary.

Use of Cookies and information collected from your computer

When you visit our website and/or BPL Sphere, our third party server may record your IP address for the purposes of systems administration and may also gather other non-personal information from you (from which BPL cannot identify you), such as the type of your internet browser which can be used to provide you with a more effective service.

Our website and BPL Sphere also uses cookies to better the user’s experience while visiting the website or BPL Sphere.

Cookies are small files saved to the users computer’s hard drive that track, save and store information about your interactions and usage of the website. This allows the website and/or BPL Sphere, through its server, to provide users with a tailored experience within either. The cookies we use are detailed below:

Users have the opportunity to adjust cookie settings when they visit our website, and can amend these at any time by navigating to the “Manage consent” link at the bottom of every website page.

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website and/or BPL Sphere but will not store, save or collect personal information. You can read Google’s privacy policy here for further information.

Social Media Platforms

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate upon them with due care and caution in regard to their own privacy and personal details. This website / its owners will never ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Before using such social sharing buttons, users are advised that they do so at their own discretion and note that the social media platform may track and save their request to share a web page.

Access through Mobile Devices

If you access our websites and/or BPL Sphere on your mobile telephone or mobile device, we may also collect your unique device identifier and mobile device IP address, as well as information about your device’s operating system, mobile carrier and your country and/or city information.

External links

This website and/or BPL Sphere may include external links to third-party websites whose privacy policies we do not control. BPL is not responsible for those websites. Although we only look to include quality, safe and relevant external links, users should always adopt a policy of caution before clicking on any third-party website links mentioned on this website.

The owners of this website and/or BPL Sphere cannot guarantee or verify the contents of any externally linked website. These third-party websites will be governed by different terms of use (including privacy notices) and users are solely responsible for viewing and using each such website in accordance with the applicable terms of use. Users click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting third-party websites linked on this website. BPL is not responsible for how users’ personal information is handled by such third-party websites.

Security

BPL maintains security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. Despite this, the security of the transmission of information via the Internet cannot be guaranteed and you acknowledge this in your access and use of our websites.

Your rights

You have various rights in relation to your personal data, which in summary are:

• right to request that we erase data e.g. if it is no longer necessary for us to hold it for the relevant purposes;
• right to find out what data we hold about you and to obtain a copy of it;
• right to rectify inaccurate data or have incomplete data completed;
• right to restrict processing to limited uses e.g. where there is a question over its
• accuracy or an objection to processing is being determined;
• right to object to processing based on BPL’s legitimate interests, unless there
• are compelling and overriding legitimate grounds for us to continue processing;
• right to object to use of your data for direct marketing;
• if you are processing your data on the basis of your consent, you have the right at any time to withdraw that consent; and
• right to obtain data in a commonly used and machine-readable format.

Your rights may be exercised by contacting us as stated below. Some of the above rights only apply in certain circumstances, but if we decline to comply with a request, we will inform you of the basis for doing so.

Questions and contacts

Any questions or enquiries which you have in relation to this Policy or practices should be submitted via the Contact page or addressed in writing to:

Compliance Officer
Berry Palmer & Lyle Limited
52 Lime Street
London
EC3M 7AF

If you have any concerns about how BPL manages your personal data, you also have the right to make a complaint to a data protection regulator. In the UK, this would be the Information Commissioner’s Office (https://ico.org.uk/).