Most of the data we collect and hold about you is for the purpose of providing you with insurance. We also use data to make Brolly’s products and services better, and to help us advertise Brolly.
To provide you with insurance
We gather information about you and your insurance risk so we can provide you with the best insurance product for you. For example, so that we can provide you with travel insurance, we’d need to know your date of birth and destination of travel.
Brolly is authorised and regulated by the Financial Conduct Authority (FCA).
To make Brolly better
We collect data on how you use our website, our app, and other features. We track and analyse things like which features you use and where you click on our website. This helps us to learn what is working well and which features we need to improve for you and other customers.
To advertise Brolly
We may use your information, defined below, to help bring the Brolly service to more people. If you’re already a member of Brolly, so that we can stop asking you to sign up, we may share your data with social media, search engines, and other advertising platforms. Brolly aim to be the best digital insurance provider on the market, so we only keep your personal information to ourselves.
Information you submit when signing up
We collect information that you submit through our app or website; for example, when you sign up you provide details such as your name, date of birth, email and address.
Through your use of Brolly
For example, when building your profile, we may collect information that you voluntarily provide to us, such as your living situation, which insurance policies you have, information about your travel behaviour and your finances, or information about your health. You have the flexibility to provide us with as little or as much information as you like.
We will only process your sensitive personal data with your consent.
Information about your insurance providers
Such as which insurance products you have and from which providers, including premiums, renewal dates and policy numbers. This ensures we can help you to organise your insurance in one place, and keep track of relevant policy information.
Brolly provides an optional ‘inbox connect’ feature. The purpose of this feature is to give our users an automated way to store and manage their insurance policies. The inbox connect feature populates your account with your insurance information. In order to comply with Google’s Restricted Scope, we only use this data to provide services to you within the Brolly app which improve your experience,such as automatically populating your insurance management portfolio. We do not use the data from your email inbox for any other purpose. We do not transfer this data to third parties.
With relation to our uses for your data or personal information, we never refer to “inbox connect”data. This data remains private, secure, and untouched by us.
Please see the IP addresses and cookies section of our Terms and Conditions to find out more about the cookies we use and how to manage them.
It’s important that you understand what we do with the data that we hold about you, as well as the legal reasons as to why we are allowed to do this.
We use the personal information we hold on you for the following purposes:
Performing our contract and service with you
We need to process information in order to help you manage your insurance portfolio, to advise you about insurance products you might need, to make recommendations of specific products suitable for you, and help you to manage your insurance portfolio
We may use your personal information to benchmark and during our research on our customers and their interactions with Brolly and our insurance partners. If we do so, we will always anonymise your data first. Where your personal information is in a pseudonymised form, Brolly will continually evaluate it to ensure that the products and services we provide are relevant to you, as well as for information on market trends.
Internal record keeping and legal compliance
Marketing by us
We may use your personal information to contact you by email about our products and/or services and our insurance partners. We will only use this information on the legal basis of your consent.
Sharing information with third party processors
We may share your personal information with third party processors in order to provide the Brolly Service and our associated products and services. We strictly only share information for data processing purposes so that you can use the Brolly service. Your data is not shared for serving ads, including retargeting, personalised, or interest-based advertising purposes for our third party processors. It is in our legitimate interest to share your personal information in a manner which ensures that we can provide the very best service we can to you. Where we share your sensitive personal data, we shall always be relying on your consent to do so.
Sharing information with professional advisors, governmental authorities & potential purchasers
We will only share your personal information with professional advisers or governmental or regulatory authorities if required to do so by law. This does not include information provided to us via the Inbox connect feature.
Your personal information may also be shared with prospective buyers if we were to go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets. It is in our legitimate interest to share your personal information with such third parties so they can process your information on our behalf, comply with and/or enforce our legal rights and obligations, protect the rights of third parties and in order to facilitate business transitions. Where we share your sensitive personal data, we shall be relying on your consent to do so.
Sharing information with other insurance providers
We will only share your personal information with our insurer partners when you have requested their services through the Brolly app or website. This information is shared in order for them to provide insurance products and services requested by you. We do not share information provided via the Inbox connect feature in the app. It is in our legitimate interest of the insurance provider for us to share your personal information with insurance providers so that they can to enable them to process your information and provide products and services to you. Where we share your sensitive personal data, we shall be relying on your consent to do so.
Any other purposes for which we wish to use your personal information will be notified to you from time to time including the legal basis of such use.
As required under the FCA regulations, Brolly stores records of a customer’s insurance risk information for 5 years after an insurance policy has expired. All of our data processors are GDPR compliant.
Although our offices and servers are based within the European Economic Area, in certain circumstances we may transfer your personal information, for the purposes of analytics, such as MixPanel. These third parties may store data in countries outside the European Economic Area in locations where laws are not recognised by the EU Commission as providing an adequate level of protection to personal information. We try to keep this to a minimum and is only used when necessary.
We keep your personal information as long as you’re using Brolly, and no longer than is necessary for the purposes for which we collected it. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer, if we need to and if the law says we have to.
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal information and “inbox connect” data that we have under our control from:
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information. In these instances, your data is anonymised and/ or aggregated. Brolly’s employees are obliged to respect the confidentiality of the personal information of all users of the Brolly Service.
You have the right to:
If you’re not happy with how we’ve handled or processed your personal information, please contact us through the app or by emailing email@example.com and we’ll do our best to resolve the problem.
If you’re still unhappy, or want further information about your rights, you can contact the Information Commissioner’s Office (ICO). You can find out how to do this by calling their helpline on 0303 123 1113 or by visiting the ICO website at https://ico.org.uk/concerns/.
For the purposes of this Policy, “we”, “us”, “our” and “Brolly” means Brolly UK Technology Limited. Unless otherwise stated, Brolly is the Data Controller for your personal data.
We’re registered with the Information Commissioner’s Office with under number ZA187415.
Brolly is an English company with registered company number 10134039 and whose principal address is 125 Charing Cross Road, Soho, London WC2H 0EW.
This Policy applies to how we use your information in relation to our products and services generally.
This Policy doesn’t apply to other companies’ sites that you get to through our website or social media pages. So make sure you’ve read their policy before putting your personal information on their site.
Last Updated: August 2019
This information tells you about the Brolly service, which enables you to learn more about your insurance and purchase cover through our app. All Brolly products are underwritten by our insurer partners. If you’d like more information on how any aspect of Brolly works, please read our FAQs here.
“We/us/our” means Brolly UK Technology Limited, 125 Charing Cross Road, London, WC2H 0EW. Our company registration number is 10134039.
We act as an Independent Insurance Broker and we are authorised and regulated by the Financial Conduct Authority (FCA), 12 Endeavour Square, London, E20 1JN. Our FCA number is 811608. You can check this out on the FCA’s register by visiting their website www.fca.org.uk/register or by contacting the FCA on 0800 111 6788.
If you wish to make a complaint, please follow the procedures outlined on our app or email Customer Support at firstname.lastname@example.org. If we cannot settle the complaint satisfactorily, you may be entitled to refer your complaint to the Financial Ombudsman Service (FOS). Details of how will be provided to you in these circumstances. Further details can be obtained by clicking here.
Online Dispute Resolution (ODR)
As our policies are sold online through our app, you may also submit a complaint through the Online Dispute Resolution (ODR) platform http://ec.europa.eu/odr.
Financial Services Compensation Scheme (FSCS)
We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim. Full details and further information on the scheme are available from the FSCS or by downloading the Protecting your Money FSCS Leaflet (PDF).
Scope of Capacity and Services
We operate a non-advised service and act on behalf of our customers and are subject to the Law of Agency which imposes duties on us. We are acting as your agent when we are 1) advising and arranging your insurance cover with Insurers to meet your requirements; 2) helping you with ongoing changes you make; 3) placing insurance on your behalf; 4) assisting you with a claim you need to make.
We are acting on behalf of the Insurer when we collect your premium, where this occurs in other circumstances, you will be advised at the time.
You will not receive advice or a recommendation from us. We may ask you some questions to narrow down the selection of products that we will provide information on, and you will need to make your own decision on how you proceed. We have conducted a review of a limited number of insurers. The insurers that we may and can conduct business with for your product are named within the Brolly app and on our website.
Your chosen Insurer will be notified to you at the point of sale. We will provide you with the information to enable you to make an informed decision regarding your cover. We will provide you with a non-advised sale.
We arrange the policy with the insurer on your behalf, you do not pay us a fee for doing this, we receive a commission from the insurer which is a percentage of the total annual premium. We are committed to ensuring complete transparency of our remuneration and we will, at your request, fully disclose our remuneration. This will include commission, fees, profit share arrangements and any volume business deals that your policy may contribute towards. Our fees are for the policy period and we will retain all fees in relation to policies we’ve placed.
Duty to Disclose
You are obliged to provide full and accurate material circumstances about your risk, now and throughout the lifetime of your policy. A material circumstance is anything that may influence an Insurers judgement in their assessment of your policy and should include all incidents or losses that you have dealt with yourself without involving an Insurer. A material circumstance could include changes to your address, criminal convictions or any financial issues such a potential bankruptcies or county court judgments. If you are unsure as to whether a circumstance is material, we recommend that it be disclosed. Failure to disclose may entitle the Insurers to refuse to pay part or all of any subsequent claims. Specific obligations also apply as per below depending on your status.
Definition of a Consumer
A policyholder acting for purposes outside their trade, business or profession.
Misrepresentations Act (Consumers only)
You have a duty to take reasonable care not to make a misrepresentation in any information that is provided by you and to answer all questions asked by Brolly honestly. Under the Consumer Insurance (Disclosure and Representations) Act 2012, a misrepresentation may amount to a failure to comply with a request from an Insurer for confirmation, or amendment, of details previously provided by you. Please be aware that the duty to take care not to make a misrepresentation exists not just prior to any placement being effected but also at any subsequent renewal and any variation of the contract terms during the period of insurance. In the event of a deliberate or reckless misrepresentation, Insurers may avoid the contract. Under the Consumer Insurance (Disclosure and Representations) Act 2012, a deliberate or reckless misrepresentation is a misrepresentation where you know it to be untrue or misleading (or do not care either way) and that you know (or do not care) that the matter to which it relates is relevant to Insurers. Insurers may also avoid the contract where a careless misrepresentation has been made. A careless misrepresentation is a misrepresentation that is neither deliberate nor reckless. In such instances, if Insurers would not have entered into the contract had the careless misrepresentation not been made, then Insurers may be entitled to avoid the contract. However, if Insurers would have imposed different terms had the careless misrepresentation not been made, then Insurers may be entitled to treat the contract as if those terms applied.
If your policy requires you to populate & update the Motor Insurance Database, it is entirely your responsibility to ensure this is done even if you request us or your Insurer to do this on your behalf. We are unable to accept responsibility if you fail in your obligations to ensure the MID is correct as per current legislation.
Use of Other Intermediaries
Where we consider it to be appropriate and for your benefit, it may be necessary for us to request another broker or intermediary to act as our agent and assist in the placement of your insurance product. In such cases, we will provide specific instructions to such sub-agents to meet your insurance requirements.
In the event that we make a charge you will be notified at the time of any such transaction.
Payment of Premiums
We only accept payment via debit card, credit card, and mobile payments, but we will give you full information about your payment options if you wish to contact us.
We do not guarantee the solvency of any Insurer we place business with. A liability for the premium, whether in full or pro rata, may arise under policies where a participating Insurer becomes insolvent.
All personal information about you will be treated as private and confidential. We are registered with the ICO as a Data Controller. We undertake to comply with the General Data Protection Regulation (GDPR) in all our dealings with your personal data. Your personal information will be kept secure. If you require more information on how we use your personal data, please refer to our privacy notice at www.heybrolly.com/legals and contact us for other rights you may have under GDPR such as ‘Rights of Data Access’ etc.
Information which you provide to us will not be used or disclosed by us to other parties, except in the normal course of handling a contract of insurance or a claim on your behalf and any related activities, unless we have obtained the necessary consent from you or where we are required to by law or a regulatory body that has authority over us. We will take appropriate steps to maintain the security of your confidential documents and information which are in our possession.
Insurers pass information to the Claims and Underwriting Exchange run by Insurance Database Services Ltd and the Motor Insurance Anti-Fraud and Theft Register run by the Association of British Insurers. The aim is to check information provided and also prevent fraudulent claims. Motor Insurance details are added to the Motor Insurance database run by the Motor Insurers’ Information Centre that has been formed to help identify uninsured drivers and may be secured by the Police to help confirm who is insured to drive. In the event of an accident the database may be used by Insurers and the Motor Insurers Bureau to identify relevant policy information. Other insurance related databases may also be added in the future.
To make sure you get the best offer from Insurers or Third Parties involved in your insurance, i.e. finance providers, now or at any renewal or at any time and to protect their customers from fraud and to verify your identity, they may use publicly available data which they obtain from a variety of sources, including a credit reference agency and other external organisations. Their search will appear on your credit report whether or not your applications proceed. As well as these searches they or we may use a credit check to ascertain the most appropriate payment options for you. This credit check will also appear on your credit report whether or not your applications proceed. Unless you contact us to confirm you do not wish us to carry out these searches we will assume your consent has been given and proceed as above.
You must notify us as soon as possible of a claim and circumstances which may give rise to a claim. In the event of a claim you should contact us and we will promptly advise you and if appropriate, pass all details to your Insurer. You should not admit liability or agree to any course of action, other than emergency measures carried out to minimise the loss, until you have an agreement from your Insurer. We will remit claims payments to you as soon as possible after they have been received on your behalf. In the event that an Insurer becomes insolvent or delays making settlement we do not accept liability for any unpaid amounts.
Cooling Off Period
We will give you enough information and help so you can make an informed decision before you make a final commitment to buy your insurance policy. However, you will have 14 days to change your mind and cancel the insurance contract from the date you receive your policy documentation.
We act as agents for the insurer for the collection of premiums and payment of claims and refunds of premiums. This means that premiums are treated as being received by the insurer when received in our bank account and that any claims money or premium refund is treated as received by you when it is actually paid over to you. There are occasions where such transactions are restricted (for example, to receiving premiums only) and we will tell you if this is the case.
Payment to Third Parties
We may transfer client money to a third party, such as another broker, for effecting a transaction on your behalf through that third party. This may include brokers or agents outside the UK. The legal and regulatory regime applying that third parties outside the UK may be different from that of the UK and in the event of a failure of that firm; this money may be treated in a different manner from that which would apply if an agent in the UK held the money. You may notify us if you do not wish your money to be passed on to a third party in a particular jurisdiction.
Your insurance may include a cancellation clause. If you are a Consumer, this is mandatory. Full cancellation details will be in your policy wording. In the event of cancellation, Insurers may return the pro rata premium to us, but you are advised to check your insurance policy for full details of your Insurers’ cancellation clause. Once our remuneration has been earned in the event that the insurance is cancelled after inception, our fees or brokerage may be returnable pro rata, minus any fees or charges incurred by our payment processing provider.
The National Crime Agency (NCA) requires us to report any suspicious transactions to them, and we may have to obtain evidence of a client’s identity at the start of a business relationship. We may ask for sight of your passport, utility bill or bank statements. For companies, evidence usually consists of a copy of the Certificate of Incorporation or we may check the Companies House register.
Our services may be terminated without cause or penalty. In the event that our services are terminated by you other than at the expiry of the policy we will be entitled to retain any fees and all of the brokerage payable. The responsibility for handling claims reported after the date of termination shall in the absence of an express agreement be the responsibility of the party taking over the role.
Law and Jurisdiction
These Terms of Business shall be governed by and construed in accordance with English law. In relation to any legal action or proceedings arising out of or in connection with these Terms of Business, we both irrevocably submit to the exclusive jurisdiction of the English courts.
Last updated July 2019