Privacy Policy

This privacy policy sets out how Heritage Health Limited (“We”) collect and use your personal data.

The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified. We will collect, use, store and transfer different kinds of personal data about you this will include:

• Your name, address, contact details and where applicable your next of kin;
• Your health and medical history and current health and or fitness status;
• Details about any contact We have had with you such as providing quotes;
• Details of the services you have received, claims you have made or treatment you have received;
• Feedback that you give to us regarding the services We have provided or the insurers We use;
• Recordings of telephone calls between you and us.

When giving us information about a family member or another person, You confirm that they have appointed you to act on their behalf including giving you consent to instruct us to process their personal data, to receive this data protection notice on their behalf and to inform them about the way in which We will process their personal data.

We do not collect or use children’s personal data except when that information is provided by an adult who has purchased a plan that also covers a child.  We do not use children’s information for any marketing activity.

How is your personal data collected?

We use different methods to collect data from and about you including:

• Directly from you: We collect personal information about you when you use our services, visit our website, or otherwise communicate directly with us.
• From your employer or representative: We may obtain personal information about you from your employer or the company with which you are affiliated in order to provide our services to them and/or manage your access to such services.
• From a third party acting on your behalf: We may collect personal information from your family members, financial advisor, doctor or other representative.
• From automated technologies: We may obtain personal information about you through automated technologies, such as cookies on our website
• From acquired entities: If we acquire an entity as part of a corporate transaction, we may obtain personal information about you from that entity.
• From other third parties: We may obtain your personal information from credit reference agencies, anti-fraud databases, sanctions lists, court judgements and other judicial databases, government agencies, open electoral register and any other publicly available data sources.

How we use your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We will collect and process your personal data in order:

• To provide you with a quote: As part of the applications to source quotations from insurance companies We collect the personal information and with your or your representative’s explicit consent we also capture information regarding your medical history. This information is required for us to assess your individual requirements, source quotes, identify any additional conditions or exclusions that may need to be applied and make a recommendation that is based on your needs. We may use information provided by healthcare professionals (to gain further information on your medical health to ensure the cover given is adequate and any necessary exclusions are identified. The legal basis for this processing is the performance of a contract with you and consent in connection with your medical history.
• To set up and administer your plan with your chosen insurer: To confirm the purchase of a plan the necessary personal information and medical history is submitted to the chosen insurer. Your chosen insurer will issue you with details of your chosen plan which will include a copy of their privacy notice. The legal basis for this processing is the performance of a contract with you.
• To assist with the renewal of your plan annually: Unless you tell us or your chosen insurer otherwise your chosen insurer will renew or continue your plan and adjust your premium and coverage amount according to the terms of your plan. We and your chosen insurer will continue to use the data you have previously provided to us for this purpose. The legal basis for this processing is the performance of a contract with you.
• To communicate with you: We will communicate with you via email, post, telephone, depending on your communication preferences and/or the methods you have chosen. The legal basis for this processing is the performance of a contract with you or for the purposes of a legal obligation.
• For compliance: To ensure we are compliant with legal and regulatory obligations, We will use your data, this will include reviewing calls between you and us. This also helps us to train our staff and to improve performance.  The legal basis for this processing is as a result of a legal obligation.
• For direct marketing: When your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email or post. We may also use your personal data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications. We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at info@heritagehealth.co.uk.  If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes. The legal basis for this processing is our legitimate interests.

Disclosures of your personal data

We may share your personal data where necessary as set out below:

• Disclosure for regulatory or legal purposes: We will only share your personal data with other companies or organisations where there is a legitimate reason for doing so.  For example We are obligated to provide information to specific Government departments such as HM Revenue and Customs and to regulatory bodies who govern our activity such as the Financial Conduct Authority and the Financial Ombudsman Service.
• Sharing your personal data with insurance companies: In order to source quotes, policy conditions and exclusions and complete the purchase of an insurance policy, it is necessary for us to share the required personal information that is collected from you or your representative with the proposed and/or chosen insurance company. This will also include sharing details of your medical history as this allows the insurer to identify any additional conditions or exclusions that need to be applied.
• Our use of other companies to provide our services to you: We use third party services for areas such as infrustructure and support. This helps us to provide a better and more secure service to customers. When using third-parties, we ensure that there is an agreement in place that meets our standards and legal requirements for data protection.

International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Cookies

Please see our Cookie Policy.

Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• [Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: info@heritagehealth.co.uk
• Postal address: Lytchett House, 13 Freeland Park, Wareham Road, Poole, Dorset, BH16 6FA
• Telephone number: 0800 131 0764

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 01^st Jan 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address