Insignia Privacy Policy

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, country of residence and nationality.
• Documentary Data includes copies of your passport, driver’s licence, ID card, proof of address and references.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Contractual Data includes details about the products or services we provide to you.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from or through us.
• Open Data includes details about you that are in public records, and information about you that is openly available on the internet.
• Social Relationships Data includes your family, friends and other relationships.
• Location Data includes data we get about where you are, for instance when we book services on your behalf.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Communications Data includes what we learn from you from letters, emails (and other forms of electronic communication) and conversations between us.
• Profile Data includes your username and password, purchases or services requested by you, your interests, preferences and feedback.
• Usage Data includes information about how you use our website, products and services
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Special Category Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, and information about criminal convictions and offences. We will only collect and use these types of data if the law requires or allows us to do so.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

We may collect personal information about you (or your business) from these sources:

Data you give us:

• When you apply for our services;
• When you talk to us on the phone;
• When you use our website;
• In letters, emails and other forms of electronic communication;
• In customer surveys or promotions;
• If your business is looking to enter into, or has entered into, a business arrangement with us.

Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients of:

• Payment and transaction data;
• Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone services.

Data from third parties we work with, or otherwise publicly available:

• Companies within the Insignia Group of Companies (please see the Glossary below for a definition of this term);
• Companies that introduce you to us;
• Fraud prevention and law enforcement agencies;
• Retailers;
• Social networks;
• Public information sources such as Companies House;
• Agents working on our behalf;
• Medical practitioners (always subject to your consent).

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you, or if we process any Special Category Data. You have the right to withdraw your consent at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us (or from another company within the Insignia Group of Companies) if you have requested information from us, if you have provided your express consent for receiving that marketing, or, in certain cases, if it is in our legitimate interest.

Third-party marketing
We will not share your personal data with any company outside the Insignia Group of Companies for marketing purposes.

Opting out
You can ask us to stop sending you marketing messages by contacting us at any time.
Where you opt out of receiving these marketing messages, you will still receive important information such as changes to your existing services.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Telephone Calls
We may monitor and/or record your telephone calls to us, or ours to you, to ensure consistent servicing levels (including staff training) and account operation, to assist (where appropriate) in dealing with complaints or disputes, and to assist us in ensuring we comply with our legal obligations.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the
table in paragraph 4 above.

• Companies within the Insignia Group of Companies as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with
the law. We do not allow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes and in accordance
with our instructions.

We share your personal data within the Insignia Group of Companies. This may involve transferring your
data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is
afforded to it by ensuring that we use specific contracts approved by the European Commission which
give personal data the same protection it has in Europe. For further details, see European Commission:
Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring
your personal data out of the EEA.

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.

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us on DPO@insignia.com.

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 may 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 may 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.

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

The Insignia Group of Companies
The Insignia Group of Companies is a family of companies operating under the trading name of “The Insignia Group of Companies” or “Insignia”. Its main operating companies are Insignia Cards Limited (Malta) and Insignia Lifestyle Boutique Limited (UK), but also includes other entities such, as Tridex UK Limited, which provide services to the operating companies. Insignia Cards Limited and Insignia Lifestyle Boutique Limited, for the most part, act as a joint controller of personal data, while other companies within the group act as processors.

External Third Parties

• Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business.
• Revenue & Customs, regulators and other authorities.
• Fraud prevention and law enforcement agencies.
• Companies we have a joint venture or agreement to co-operate with.
• Organisations that introduce you to us.
• Companies that we introduce to you.
• Companies you ask us to share your data with.
• Organisations we need to share your personal information with to provide you with the product or service you have chosen (e.g. retailers, hotels, airlines, etc).

We may also share your personal information if the make-up of The Insignia Group of Companies changes in the future:

• We may choose to sell, transfer, or merge parts of our business, or our assets. Or we seek to acquire other businesses or merge with them.
• During any such process, we may share your data with other parties. We will only do this if they agree to keep your data safe and private.
• If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

Your legal rights

You have rights to:
Request access to your personal data (commonly known as a “data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.