- Who we are
- How we collect your personal data
- How we use your personal data
- Your rights
Who we are
Protecting the privacy and personal information of our visitors is of the utmost importance to us. This Privacy Notice sets out how we handle the information we learn about you when you visit this website, how we use it, and your rights in relation to how we hold and process this information. Capital Life offers a number of products and services. This Privacy Notice applies to all the legal entities within Capital Life Group Limited (including Capital Life Legal Services Limited, Capital Life Law Limited, and Capital Life Funeral Planning Limited) to the extent that they are controllers and/or processors of your personal information, registered in England & Wales, company number 11063711, registered address: Brooke Court, Lower Meadow Road, Handforth, Wilmslow, SK9 3ND.
When you use this site you trust us with your information. By helping you understand our privacy practices, we want to show that we are committed to keeping that trust. This Privacy Notice (together with our Terms & Conditions and any other documents referred to in it), describes how we collect and use personal information about you in accordance with the UK General Data Protection Regulation (GDPR).
It is important that you read this Notice in conjunction with any other Privacy Notice which we may provide on specific occasions so that you are aware of how we are collecting or processing information about you and why we are using such information.
You can contact us directly about how we use your personal information or to exercise your data subject rights:
This Privacy Notice only covers our website and does not extend to other third-party websites accessed from this website. If you follow a link to a third-party website, please be aware that they will have their own privacy notices and that we do not accept any responsibility or liability for third-party Privacy Notices. Please check all applicable third-party Privacy Notices before submitting any personal information.
How we collect data about you
We may collect and process the following information about you (“your information” or “your data”):
- Information that you provide by filling in forms on our site, such as your full name, address, email address and telephone number, or additional information you provide when applying for any of the products and other services we offer via telephone.
- If you have been nominated as a representative, we will collect your full name, address and email address as provided by the Plan Purchaser.
- We may ask you for information if you report a problem with our site, or if you contact us and request assistance with using our site.
- The contents of any correspondence you send us.
- Details of products and services you have purchased, your visits to our site including but not limited to; traffic data, location data, web logs and other communication data, whether it is required for our own purposes or otherwise, as well as the resources that you access by using our website.
- Information obtained from third party data suppliers that you have consented to providing or information that is publicly available about you.
IP addresses and Cookies
We may collect information about your computer for system administration, including where available your IP address, operating system, and browser type. This information is statistical data about our users’ browsing actions and patterns. We do not link our users’ IP address to a person’s personal data which means that whilst we have a record of a user’s session, they will remain anonymous to Capital Life.
How we use your personal data
Personal data includes any information that directly or indirectly identifies you. The information you provide to us will depend on the product or service you have requested but can include name, address, date of birth, contact details, payment details or any other information you provide as part of the application process for the purpose of buying our products or services.
We also receive personal information from Third Party Data Providers that you have consented to providing or information that is publicly available about you.
Sensitive Personal Data
In addition to the personal data about you that we process, it may also be beneficial to be aware of any medical or health conditions you have so that we are aware of these conditions, how they affect you and in turn, make reasonable adjustments to accommodate your specific needs when offering our products or services to you. We require your explicit consent to process this type of information.
The principal purpose of collecting personal data from you via this website is to provide information, products or services specifically requested by you. When you complete our online forms, we ask for your personal details and other selected information so that we can deal with your request as efficiently and effectively as possible.
Why do we process your personal data?
Capital Life collects and may obtain data purchased from third party providers. Under UK GDPR, there are six lawful bases for processing data. Capital Life Group subsidiaries process data we collect or obtain under the following legal bases:
Processing of your personal data is necessary to:
- Ensure that content from our site is presented in the most effective and user-friendly manner for you and your device.
- Verify your identity including anti-money laundering checks. We also use your personal data for crime and fraud prevention purposes.
- Meet our regulatory compliance and reporting obligations.
- Enforce any of our rights against you.
- Develop and improve our services to you and notify you about changes to our services.
Processing of your personal data is necessary to:
- Process your request for a quote or your application for products or services you have purchased.
- Fulfil our contract with you when purchase a product or service from one or more of Capital Life Group’s subsidiaries.
- Carry out our contractual obligations in respect of the provision of your plan and the provision of our services.
When you purchase any of our products, we may process your data for direct marketing purposes by telephone, email, SMS, or postal. We will only process your data in this way if you have clearly given your consent by ‘opting in’ to receiving further communications from Capital Life.
How we store your personal information
Your information is stored securely. Please see our Data Retention Policy for information on how long we hold your data for.
Disclosure of your information
We may disclose your information to any member of our group, which means that we may disclose your information to our ultimate holding company and its subsidiaries.
Other than as described in this Notice, we will never transfer, sell, trade, or rent your personal information to others. However, we may share your information with selected third parties in the following instances:
If it is necessary for us to fulfil a contract with you, we may share your information with our business partners, suppliers and subcontractors, but only with your consent. We partner with the following lists of groups, suppliers and subcontractors in order to manage your Plan. In some cases, they may process personal data, for example, to provide an identity verification check.
Group companies and subsidiaries, including Capital Life Ltd, Capital Life Funeral Planning Limited, Capital Life Law Limited and Capital Life Legal Services Limited
Amazon Web Services
Quote My Life
In the event that we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets. In such an event, we will ensure that the prospective seller or buyer treats your information as confidential.
If a third party acquires Capital Life Group or any of its subsidiary companies, or substantially all of its assets, in which case information held by its subsidiary companies about its customers will be one of the transferred assets. In such an event, we will ensure that the third party treats your information as confidential and in accordance with legal, data protection and privacy obligations
If we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation, as part of legal proceedings, to enforce or apply our terms and conditions which apply to your products and services or to protect the rights, property, or safety of Capital Life Group subsidiaries, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
You have a number of specific rights under the UK GDPR. The rights available to you depend on our reason for processing your personal data. You are not required to pay any charge for exercising your rights. You must contact us using any of the methods detailed in this Notice if you want to exercise any of these rights and we have one month to respond to you:
Right to withdraw consent
Where we have processed your data based on your consent, you can withdraw your consent at any time by unsubscribing from our emails or alternatively, contacting us using any one of the contact methods listed in the ‘Contact Us’ section in this Notice.
Right to rectification
We will take reasonable steps to keep your information accurate, complete and current, but you can also ask us to change any information we hold about you to keep it that way. Please remember that it is your responsibility to tell us about any updates to your information.
Right to access your personal data
You can request a copy of the personal information that we hold about you. This is known as a ‘Data Subject Access Request.You can make a ‘Data Subject Access Request’ by using any of the contact methods detailed in the ‘Contact Us’ section in this Notice. We may ask you to provide us with a form of approved identification in order for us to verify your identity.
Right to be forgotten
In certain circumstances, you have the right to ask us to delete the personal information we hold about you, for example, if your personal information is no longer necessary for the purposes it was collected for, or your personal information has been processed unlawfully. There are legitimate reasons that we must retain some of your personal information after you have requested its deletion, including compliance with legal or regulatory obligations to which we are subject, or for any legal claims.
Right to request a restriction on our processing of your personal information
You can request that we restrict our processing of your personal information in specific circumstances. Where a restriction is in place, we can continue to store your information, but we will only process it with your consent or for legal, individuals’ rights or important public interest reasons. We will inform you prior to the lifting of any restriction(s).
Right to object to our processing of your personal information
When our processing of your information is performed on the basis of ‘legitimate business interest’ you can request we stop the processing. We can continue to process your information for the establishment, exercise or defence of legal claims if we demonstrate compelling legitimate grounds which override your interests, rights or freedoms.
Right to data portability
You can request that information you have provided to us, is transferred to you or another data controller where this is technically feasible.
We may create a profile based on your preferences and behaviour for marketing purposes and/or to detect and reduce fraud risk. In certain circumstances, you can request that your personal data is not processed in this way if it has legal or similarly significant effects on you.
Right to complain to a supervisory authority
If you are dissatisfied with our use or management of your personal information, you have the right to raise a complaint to the Information Commissioner’s Office, the UK’s independent data protection regulator. You can contact the ICO in writing: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, through their website: www.ico.org.uk or by telephone: 0303 123 1113
If at any time you believe that we have not complied with data protection principles, please notify us by sending an email to firstname.lastname@example.org, and we will investigate your concerns and take all reasonable steps to resolve the matter promptly.