Privacy Policy

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Kingsway collects and processes your personal data through your use of this website and contact with the business, including any data you may provide through this website when you sign up to our newsletter and/or purchase a product or service from us. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Kingsway Group Global Limited and Kingsway Group, Inc. (US) are the controllers and responsible for your personal data (collectively referred to as Kingsway, “we”, “us” or “our” in this privacy policy). Kingsway Group Global Limited is made up of different legal entities and specifically Kingsway Group, Inc. (US) is a wholly owned subsidiary of Kingsway Group Global Limited. This privacy policy is issued on behalf of the Kingsway Group so when we mention Kingsway, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Kingsway Group responsible for processing your data Kingsway Group, Inc. (US) is the controller and responsible for this website. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights in relation to personal data, please contact [email protected].

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager: Email: [email protected] Post: Unit 2, Tear Drop Industrial Park, London Road, Swanley, Kent, BR8 8TS Telephone: 01322 610470. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 31 May 2021. Historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name and company (usually employer.)
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your interests, preferences, feedback and personal communications with us.
• Usage Data includes information about how you use our website and whether this results in enquiries or purchases of our products and services, either personally or on behalf of another business.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Unless you apply for a job role with us, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).  Nor do we collect any information about criminal convictions and offences.

If you apply for a job role with us, we may also collect, store and use the following more sensitive types of personal information both during the recruitment process and during your employment: Special Category Data (for employees and applicants for job roles) about:

• your race or ethnicity
• trade union membership.
• Information about your health, including any medical condition, health and sickness records, including:
  • where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;
  • details of any absences (other than holidays) from work including time on statutory parental leave and sick leave;
  • any health information in relation to a claim made under the permanent health insurance scheme; and
  • where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
• Information about criminal convictions and offences. Successful candidates for a job role will be issued further details of our Employee Privacy Policy. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions.

You may give us your Identity, Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties: Technical Data from the following parties:
  • analytics providers such as Google based outside the UK; and
  • search information providers; Contact, Financial and Transaction Data from you directly or from providers of technical and marketing services.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us (or on behalf of your employer) and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties e.g. within the Kingsway group of companies
• External Third Parties who provide services to Kingsway
• Google LLC (based in the USA)
• Dropbox International Unlimited Company (based outside the USA)
• Salesforce.com Inc (based in the USA)
• Online banking providers (based in the UK)
• Sendinblue (based in the EU)
• CMS managed by Hello Communications (based in UK)
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We share your personal data within the Kingsway Group. Many of our external third parties are based outside the US so their processing of your personal data will involve a transfer of data outside the US. Whenever we transfer your personal data out of the US, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Where we use certain service providers, we may use specific contracts approved for use in the US which give personal data the same protection it has in the US, either through the use of standard contractual clauses or the implementation of binding corporate rules by the service provider.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the US.