Protecting your personal information is extremely important to Inspired Villages. The way we collect, use, share and protect your information is equally important as you trust us to manage your information confidentially and securely.
This Privacy Notice tells you how we collect and process your personal information. Please take a few minutes to read it and show it to anyone else to whom it may apply.
This Privacy Notice was last updated: 30th January 2020.
- What is personal information?
When we talk about personal information, we mean information about an individual that can identify them, like their name, address, e-mail address, telephone number and financial details. It can relate to customers, employees, shareholders, business contacts and suppliers. Any reference to “information” or “data” in this policy is a reference to personal information about a living individual.
- What information do we collect?
- We may collect and process the following personal information about you:
Type of information Description Examples of how we use it Contact details
Who you are
Where you live
How to contact you
Marketing our villages close to you
Analysis & profiling
Enhancing our product and service offering
Sending offers relevant to you
Lifestyle and social circumstances
Analysis & profiling
Consent & preferences Ways you want us to market to you Marketing Technical Details on the devices and technology you use Making sure our products and services are fit for purpose Documentary data & national identifiers
Details about you that are stored in documents like:
- Your passport
- Drivers licence
- Birth certificate
- National insurance number
Prevent financial crime
- How do we collect your information?
Information you give us directly (when you fill in forms or contact us by phone, e-mail etc.).
- How do we use your information?
We use personal information that we hold about you:
- To carry out our responsibilities resulting from any agreements you’ve entered into with us and to provide you with the information, products and services that you’ve asked from us.
- To provide you with marketing information about services and products we offer across the Inspired Villages which may be of interest to you. Based on your marketing preferences, we may deliver this information by post, telephone, e-mail, SMS or personalised online marketing via our own systems social media platforms and/or other third party websites e.g. YouTube. Please note that if you choose not to receive online marketing, you will not see personalised messages using your personal data, however you may still see generic online advertising. We will not sell your data to third parties for them to market to you. We may also send marketing to you using our “legitimate interests”, please see below for further information.
- To tell you about changes to our services and products.
- To comply with any applicable legal or regulatory requirements (including “know your customer” checks, or to comply with any applicable regulatory reporting or disclosure requirements).
- For carrying out market research, statistical analysis and customer profiling to help us to improve our processes, products and services and generate new business (e.g. to understand digital behaviours, identify lifestyle and care attitudes and develop more engaging communications).
- To run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit.
- For any other purpose that we’ve agreed with you from time to time.
When you apply for a product or to receive a service from us, the application form you fill out or the resulting contract may contain additional conditions relating to the way we use and process your personal information. These will apply in addition to the above uses.
In some cases, we may use systems to make automated decisions (including profiling) based on the personal information we have or collect from others. These may include:
- The prevention and detection of fraud.
- Personalising the content and design of communications and online services.
- Determining when to provide tailored servicing communications (e.g. changes in your personal circumstances or lifestyle), and the appropriate channel(s) to use.
- Using your information in accordance with data protection laws
Data protection laws require us to meet certain conditions before we’re allowed to use your personal information in the way we describe in this Privacy Notice. We take these responsibilities extremely seriously. To use your personal information, we’ll rely on the following conditions, depending on the activities we’re carrying out:
- Providing our contracts & services to you: We’ll process your personal information to carry out our responsibilities resulting from any agreements you’ve entered into with us and to provide you with the information, products and services you’ve asked from us, which may include online services.
- Complying with applicable laws: We may process your personal information to comply with any legal obligation we’re subject to.
- Legitimate interests: To use your personal data for any other purpose described in this Privacy Notice, we’ll rely on a condition known as "legitimate interests". It’s in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively. We may use your information to:
- Carry out market research and product development, which can include creating customer demographics and/or profiling. We may sometimes work with carefully selected third parties to do this, for example using advertising services provided by organisations such as Google or Facebook and may share data with them, which could be combined with the information they hold about you.
- Continue to send marketing information, via post only, to customers who asked for us to provide information about our villages before 25th May 2018 and did not opt-out, until such time as they have reviewed their marketing preferences (which can be done at any time).
- Develop and test the effectiveness of marketing activities.
- Develop, test and manage our brands, products and services.
- Study and also manage how our customers use products and services from us and our business partners.
- Manage risk for us and our customers.
This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.
The outcome of this assessment will determine whether we can use your personal data in the ways described in this Privacy Notice (except in relation to marketing, where we’ll always rely on your consent). We’ll always act reasonably and give full and proper consideration to your interests in carrying out this assessment.
- Consent: We may provide you with marketing information about our services or products where you’ve provided your consent for us to do so.
You may opt out of marketing at any time by e-mailing or telephoning our Village Advisers.
- Special category (sensitive) data: Where you have consented, we will process any medical & health, racial & ethnic origin, genetic & biometric or sex life & sexual orientation information you have provided, and any other sensitive information obtained from a third party (e.g. your GP or other medical professional), solely for the purposes of allowing us to manage the provision of care within our villages.
Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.
- How long do we keep your information?
We’ll keep your personal information in accordance with our internal retention policies. We’ll determine the length of time we keep it for based on the minimum retention periods required by law or regulation. We’ll only keep your personal information after this period if there’s a legitimate and provable business reason to do so.
- Who do we share your personal information with?
We will disclose your information to:
- Other companies within the Inspired Villages Group, third-party suppliers, contractors and service providers for the purposes listed under “How we use your information?” above.
- Selected third parties, so that they can contact you with details of the services that they provide, where you have expressly opted-in or consented to the disclosure of your personal data for these purposes.
- Our regulators, government (e.g. HMRC) and law enforcement or fraud prevention agencies, reassurers, as well as our professional advisers etc.
Additionally, we may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we’ll disclose your personal data to the prospective seller or buyer of such business or assets.
- If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- If you have been dealing with a financial adviser, we’ll provide information about your product and, where appropriate, and with other information about your dealings with us, to enable the adviser to give you informed advice.
- In order to enforce or apply the terms of any contract with you.
- If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
- To protect you and Inspired Villages from financial crime, Inspired Villages may be required to verify the identity of new and sometimes existing customers. This may be achieved by using reference agencies to search sources of information relating to me (an identity search). This will not affect my credit rating. If this fails, Inspired Villages may need to approach me to obtain documentary evidence of identity.
If you’ve been introduced to us by another company (such as an estate agency), we may share your information with them to enable them to:
- Carry out market research, statistical analysis and customer profiling.
- Where you have consented, send you marketing information by post, telephone, e-mail and SMS about their products and those of carefully selected third parties.
- Assist you with your application process.
- Fraud prevention
Inspired Villages will check your details with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We may also share information about you with other organisations and public bodies, including the police and we may check and/or file your details with fraud prevention agencies and databases.
Inspired Villages and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
- Checking details on reservation.
- Recovering debt.
- Checking details of job applicants and employees.
Inspired Villages and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
Inspired Villages may also check the details of other parties related to your contract, including verification of identity. This includes beneficiaries, trustees, settlors, third party premium payers, executors or administrators of your estate, parties with power of attorney and any other beneficial owner.
- Transferring your information outside the EU
The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom or European Economic Area ("EEA") to third-party suppliers, delegates or agents. We’ll take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this Privacy Notice.
We’ll only transfer your data to a recipient outside the EEA where we’re permitted to do so by law (for instance, (A) where the transfer is based on standard data protection clauses adopted or approved by the European Commission, (B) where the transfer is to a territory that is deemed adequate by the European Commission, or (C) where the recipient is subject to an approved certification mechanism and the personal information is subject to appropriate safeguards, etc.).
Unfortunately, sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.
- Your rights and how to exercise them
You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner’s website. If you wish to exercise any these rights, please get in touch with our Village Advisers. Alternatively, you can also use the Contact Us section of our website.
- The right to access the personal data that we hold about you.
- The right to make us correct any inaccurate personal data we hold about you.
- The right to make us erase any personal data we hold about you. This right will only apply where for example):
- We no longer need to use the personal data to achieve the purpose we collected it for
- You withdraw your consent if we’re using your personal data based on that consent
- Where you object to the way we use your data, and there is no overriding legitimate interest
- The right to restrict our processing of the personal data we hold about you. This right will only apply where for example:
- You dispute the accuracy of the personal data we hold
- You would like your data erased, but we require to hold it in order to stop its processing
- You have the right to require us to erase the personal data but would prefer that our processing is restricted instead
- Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.
- The right to object to our processing of personal data we hold about you (including for the purposes of sending marketing materials to you).
- The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.
- The right to withdraw your consent, where we’re relying on it to use your personal data (for example, to provide you with marketing information about our services or products). You dispute the accuracy of the personal data we hold
- Contacts and complaints
If you have any questions about this Privacy Notice or wish to exercise any of your rights, including changing your marketing preferences, please get in touch with your usual Inspired Villages contact or our Village Advisers or click on Contact us.