Privacy policy for Careless Technologies Limited (careless™), company number 14504628, an InsurTech startup providing mobile-only insurance solutions for UK consumers.
1. Introduction
Careless Technologies limited ("we", "us", "our") is an insurance intermediary registered at 71-75 Shelton Street, Covent Garden, London,WC2H 9JQ, registration number 14504628. We are an Appointed Representative of Stubben Edge (Risk) Limited who are authorised and regulated by the Financial Conduct Authority, Firm Reference Number 943286. You may check this on the Financial Services Register by visiting the FCA's website, register.fca.org.uk or by contacting the FCA on 0800 111 6768
We are committed to the privacy, confidentiality, and protection of personal data. This Privacy Policy outlines our procedures in relation to the collection, use, and storage of personal information.
Data Collection, Source and Types of Information collected:
We collect personal data from you when you access our website, interact with our services, or communicate with our team. This may include, but is not limited to, your name, email address, phone number, IP address, payment information, and other relevant data required to provide our services.
We collect this information to:
• Provide you with your insurance cover and to meet our obligations.
• Respond to queries and provide customer support.
• Provide, maintain and improve our services.
• Comply with our legal obligations.
Under the General Data protection Regulation (GDPR), the lawful basis we rely on for processing this information is the contractual obligation we have with you when quoting and arranging insurance for you which is necessary for the performance of the contract or in order to take steps at your request to enter into a contract.
You do not have to give your consent however if you do not give your consent this may affect our ability to provide the insurance cover from which you benefit and may prevent us from providing cover for you.
By using our site, App and services, you signify your acceptance of this Privacy Policy. If you do not agree, please refrain from using our site and services. Your continued use following any changes to this policy will be deemed as your acceptance of those changes.
2. Information Sharing
We may share your data with trusted third parties for the purposes set out above, such as with:
• Insurance partner.
• Third party claims handlers, loss adjusters, private investigators, legal advisors, accountants, auditors and professional service firms.
• Third parties who provide you with service relating to your product (e.g. legal expenses).
• Our regulators and law enforcement as necessary for fraud prevention and detection.
• Financial crime detection agencies, sanction checking providers and third parties who maintain fraud detection data bases or provide assistance with investigations in cases of suspected fraud.
• Insurance industry bodies including ELTO (where required) and the association of British Insurers.
• Credit reference agencies.
We will not share your personal data with anyone outside of the European Economic Area (EEA). Automated processing and Profiling
In order to determine insurance limits and insurance premiums and to understand patterns, it requires that we may compile and analyse information in respect of all customers to model such likelihood's. We may use the information for profiling to determine both the risk and the premium price for you and other insureds based on similar exposures and risks.
Where a decision is necessary in relation to your insurance policy sometimes, we may make decisions using automated means. The automated process will consider the information that you provide us (for example, details of the property that you wish to insure), as well as other information such as postcode, information resulting from analytics and crime rates to determine whether your application for insurance can be accepted and the associated premium. Where we make automated decisions about you using your personal information, you may request that the decision is verified to confirm that the automated decision has been made correctly as well as to ask that it be reviewed by an individual decision maker.
3. Your Data Protection Rights
In accordance with data protection law, you have certain rights related to your personal data. These include:
• The right to be informed: You have the right to be informed about the collection and use of your personal data.
• The right to request access to your personal data: You have the right to access and receive a copy of your personal data and other supplementary information that we hold.
• The right to request correction of your personal data: You have the right to ask us to rectify personal information you think is inaccurate, you also have the right to ask us to complete information you think is incomplete
• The right to request erasure of your personal data: You have the right to ask us to erase your personal information in certain circumstances
• The right to restriction of processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• The right to object to processing of your personal data: You have the right to object to the processing of your personal information in certain circumstances.
• The right to data portability: You have the right to data portability which allows you to obtain and reuse your personal data for your own purposes across different services.
• The right to withdraw consent at any time.
For more information and guidance on these rights, you can refer to the official guidance provided by the Information Commissioner's Office (ICO) on their website.
You are not required to pay any charge for exercising your rights, unless we think your request is repetitive or excessive. Where a fee is necessary, we will advise you before proceeding with your request. If you make a request, we have one month to respond to you.
Please refer to the "how to contact us section" for our details if you wish to make a request.
4. Data Security
We employ robust technical and organisational measures to ensure the security of your personal data
5. Data Retention Periods
We retain personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy and for as long as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Thereafter, we will keep your personal information for as long as necessary:
• To respond to any questions, complaints or claims made by you;
• To retain records required by law or regulatory bodies.
We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal data We maintain a data retention policy which we apply to the records we hold.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
6. Policy Updates
We keep our privacy policy under regular review and may occasionally make updates. Any changes will be posted on this page with an updated effective date.
7. How to Contact Us
Should you have any queries regarding this Privacy Policy or information we hold on you, please contact us at support@wearecareless.com or via our APP, or website www.wearecareless.com
8. How to Complain
If you have any concerns about our use of your personal information, you can make a complaint to us by contacting us at support@wearecareless.com or via our mobile APP, or our website www.wearecareless.com.
If you would like to contact the Principle Insurer, Stubben Stubben Edge (Risk) Limited (No 09073942) you can do so via email at complaints@stubbenedge.com.
You can also complain to the Information Commissioner's office (ICO) if you are unhappy with how we have used your data
The ICO's address is:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow, Cheshire
SK9 5AF
Helpline number : 0303 123. 1113
ICO website: www.ico.org.uk
