Optio Group Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.optiogroup.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
means Optio Group Limited, a limited company registered in England under company number 11032254, whose registered and trading address is 10th floor, 1 Minster Court, Mincing Lane, London, EC3R 7AA, United Kingdom.
2. Information About Us
- 1. Our Site is owned and operated by Optio Group Limited, a limited company registered in England under company number company number 11032254, whose registered and trading address is 10th floor, 1 Minster Court, Mincing Lane, London, EC3R 7AA, United Kingdom. For more information about the Optio Group, please visit their website at https://www.optiogroup.com
- Our VAT number is GB 239437876.
- The person responsible for Data Protection can be contacted by email at DPO@optiogroup.com, by telephone number 0203 859 2151 or by post 10th floor, 1 Minster Court, Mincing Lane, London, EC3R 7AA, United Kingdom.
Optio Group Ltd. is the holding company for:
- Ascent Underwriting LLP, a registered Lloyd’s Coverholder;
- Cove Programs Insurance Services, a US General Agency;
- Bay Risk Services Ltd, a registered Lloyd’s Insurance Broker;
- Northcourt Limited, a registered Lloyd’s Coverholder;
- Brockwell Capital Limited, a registered Lloyd’s Coverholder;
- Optio Underwriting Limited, also trading as Cove Program Underwriting, a registered Lloyd’s Coverholder; and
- Optio Europe Brokers Ltd, a Maltese regulated insurance intermediary.
3. What Does This Policy Cover?
Our webSite may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
4. Your Rights
- As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
- The right to withdraw consent – i.e we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
3. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
4. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
- business/company name
- job title;
- contact information such as addresses, email and telephone numbers.
6. How Do We Use Your Data?
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account;
- Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link provided in the email.
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email; telephone; text message; post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- Customer details and insurance policies are kept indefinitely in order to support any future claims made.
7. How and Where Do We Store Your Data?
- We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
- Steps We take to secure and protect your data include:
- Regularly changing all passwords to such devices as laptops, computers. Ensure all computers are secure and locked if not in direct use.
8. Do We Share Your Data?
- Subject to section 8.2, We may share some of your data with third parties as outlined below.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal and/or regulatory obligations, a court order, or a governmental authority.
- We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected, by requiring all companies within the group, to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
- Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
- We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
8. What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
- In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us, which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information
- You may access certain areas of Our Site without providing any data at all.
11. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). This is known as a “Subject Access Request”. Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in section 14. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14. To make this as easy as possible for you, a Subject Access Request Form can be made available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Optio Group Limited (“Optio,” “we,” “us,” “our,” or the “Company”) is sensitive to privacy issues on the Internet and is committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”) and individuals who register to use the Services offered by the Company (“Customers).
Optio Group is the Data Controller for human resource (HR) data of own staff, non-HR data of its agents and personal data of visitors.
In general, we utilize both non-personal and personally identifiable information that you provide to us or that we collect in the normal course of business (to communicate with you about our service and product offerings) and deliver those offerings in an efficient manner. For these purposes, Optio Group employees, authorised contractors and third-party agents (usually referred as our internal data subject) will have access to some or all of this non-personal and personally identifiable information. We will always endeavour to protect this information, hold it in confidence, and ensure it is secure.
Unless specifically stated otherwise, the information you provide or that is associated with you is never shared with anyone other than Optio Group employees, authorised contractors and agents. Optio Group never trades or sells its personal information except as provided in this policy.
Information We Collect
Information you voluntarily provide to us
Information we collect automatically
Use and Disclosure of Personal Information
We may use and disclose Personal Information only for the following purposes:
To promote use of our services to you
For example, you have been signed up to use OPTIOCONNECT and we have enhanced coverages or a new product, we may send you an email inviting you to have a look. We may also send you information more generally about our products and services. You can stop receiving our promotional emails at any time by following the unsubscribe instructions included in the emails we send.
To send you informational and promotional content and event invitations in accordance with your marketing preferences
We may send you information about our products and services. We may also invite you to marketing events. You can stop receiving our promotional communications at any time by following the unsubscribe instructions included in the materials that we send.
To send you System Alert messages
To communicate account information and provide customer support
This may include developing tools and algorithms that help us prevent violations.
To protect the rights and safety of users and third parties, as well as our own
To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms
To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements
To prosecute and defend a court, arbitration, or similar legal proceeding
To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements
To provide, support, and improve the service we offer
This includes internal record keeping and our use of the data internally to assist bug fixes and testing.
To provide suggestions to you
This includes adding features that uses data to suggest other products or services that you may be interested in or that may be relevant to you.
To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition
Third Party Websites
Security & Compliance
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, administrative and managerial procedures.
OPTIOCONNECT currently uses at least TLS v1.2 (a strong protocol) encryption on all web pages. This is designed to protect the confidentiality of your personal information as it is transmitted to us over the Internet.
We do not capture or store credit card information.
OPTIOCONNECT accounts require a username and password to log in. You must keep your password secure, and never disclose it to a third party. As it is so sensitive, they are encrypted. As we cannot see them, we cannot resend forgotten passwords and users can only reset them.
If a security breach causes an unauthorized intrusion into our system that materially affects you, then Optio team will notify you, as appropriate, as soon as possible and later report the action we took in response.
Optio Group may employ independent contractors to help manage data services, and such contractors may have access to data, similar to the access we give our employees. For example, we may choose to use a third-party application service to manage our documents and emails, including personally identifiable information, with such a service provider.
Optio Group maintains contracts with these third-party service providers ensuring their access, use and disclosure of personal data in compliance with this policy.
These service providers are authorized to use your personal information only as necessary to provide the requested services to us.
Accuracy and Retention of Data
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes.
Our offices are based in the UK and cloud servers are hosted in the UK.
Optio Group has a contractual arrangement with Microsoft Azure for hosting IT Systems.
Optio Group has a contractual arrangement with MailChimp for email marketing campaigns.
Optio Group Ltd.
Attn. Data Protection Officer
10th Floor, 1 Minster Court, Mincing Lane, London EC3R 7AA, United Kingdom
We may retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
Rights to your Personal Data
Opt-out (Right to Restrict Processing)
You may contact us anytime to opt-out of, (i) direct marketing communications, (ii) our collection of personal data. Please note that your use of the Optio website and OPTIOCONNECT application may be ineffective upon opt-out.
Access (Right to be informed, Right of Access)
You may request access to your data we hold about you at any time by contacting us directly at DPO@optiogroup.com
Amend (Right to Rectification)
You can also contact us to update or correct any inaccuracies in your personal data (applicable for website users). Registered users of Optio application may review, update, correct or delete the Personal Information in their User account by contacting us at DPO@optiogroup.com . If you have contacted Optio for sales or marketing purposes and you need your personal information updated, you can contact us to change or delete your information.
Move (Right to Data Portability)
Your data is portable – i. e. you have the flexibility to move your data to other service providers as you wish.
Erase and forget (Right to Erasure)
In certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.