Privacy Policy

PRIVACY NOTICE


ABOUT US

First4Recovery Ltd are a Registered company in the UK
(Company no. SC278548) Our registered address is 61 George
Street, Perth PH1 5LB.

PURPOSE OF THIS NOTICE

This Notice is designed to help you understand what kind of
information we collect and how we may use this. In the course
of providing you with products and services we will collect
and process information that is commonly known as personal
data.

This Notice describes how we collect, use, share, retain and
safeguard personal data.
This Notice sets out your individual rights; we explain these
later in the Notice but in summary these rights include your
right to know what data is held about you, how this data is
processed and how you can place restrictions on the use of
your data.

WHAT PERSONAL DATA DO WE COLLECT?

Personal data is information relating to an identified or
identifiable natural person. Examples of the information we
may collect include an individual’s name, address, email &
telephone number.

PERSONAL DATA WE COLLECT

In order for us to administer our products we will collect
and process personal data about you. We will also collect
your personal data where you request information about our
services, customer events, promotions and campaigns.
You may provide us with personal data when completing online
quote or contact forms, when you contact us via the
telephone, when writing to us directly or where we provide
you with paper based forms for completion or we complete a
form in conjunction with you.
We will share your personal data within our firm and with the
companies connected with the performance of the products you
have purchased.

We also share personal data with authorised third parties,
this is necessary where we are required to do so by law,
where we need to administer our business, to administer your
product, invite renewals and to process claims. Some examples
follow:
Underwriters;
Maintenance and Repair Companies
Breakdown Recovery Companies;
Claims handling companies;
Company Accountants;
Regulators.

We will collect your personal data when you visit our
website, where we will collect your unique online electronic
identifier; this is commonly known as an IP address.

We will also collect electronic personal data when you first
visit our website where we will place a small text file that
is commonly known as a cookie on your computer. Cookies are
used to identify visitors and to simplify accessibility, and
to monitor visitor behaviour when viewing our website
content, navigating our website and when using features. For
more information please see our Cookie Policy.
We may record your communications with us when contacting our
customer care, complaints and other customer focused
functions.

Where we collect data directly from you, we are considered to
be the controller of that data i.e. we are the data
controller. Where we receive your data via a third party we
will be a data processor. Where we use third parties to
process your data, these parties are known as processors of
your personal data. Where there are other parties involved
in administering your products they may also process your
data in which circumstance we will be a joint data controller
of your personal data.

A data ‘controller’ means the individual or organisation
which, alone or jointly with others, determines the purposes
and means of the processing of personal data.

A data ‘processor’ means the individual or organisation which
processes personal data on behalf of the controller.

As a provider of Warranty and Breakdown Recovery Products, we
will process the following categories of data:
Personal data such as an individual’s name, address, contact
details and details of historic claims

If you object to the collection, sharing and use of your
personal data we may be unable to provide you with our
products and services.

For the purposes of meeting the Data Protection Act 2018
territorial scope requirements, the United Kingdom is
identified as the named territory where the processing of
personal data takes place.

If you require more information about our processes or
further details on how we collect personal data and with whom
we share data with, please contact our Data Privacy
Representative at Momentum Warranties Ltd, King James VI
Business Centre, Friarton Road, Perth, PH2 8DY or by email
HYPERLINK "mailto:admin@momentumwarranties.co.uk"
admin@momentumwarranties.co.uk.

WHY DO WE NEED YOUR PERSONAL DATA?

We will use your personal data for the performance of our
contract with you, to provide you with products and services,
to process claims and renewals, to administer your products,
to respond to any requests from you about services we provide
and to process complaints.

In purchasing our products and services you should understand
that you are forming a contract with us. If you contact us
for a quote or request details on the services we provide, we
consider ourselves as having a legitimate business interest
to provide you with further information about our services.

We will retain your personal data at the end of any
contractual agreement for a period of 6 years. Where you
have submitted a claim, we will retain your data for a period
of 6 years. Where you have requested a quote, we will retain
your personal data for a period of 6 months, where you have
contacted us for details of our services and products, we
will retain your personal data for 6 months. Where you have
made a complaint we will retain the data for 3 Years. Where
you or law enforcement agencies inform us about any active
investigation or potential criminal prosecution, we will
comply with legal requirements when retaining this data.

The retaining of data is necessary where required for
contractual, legal or regulatory purposes or for our
legitimate business interests for statistical analysis
(profiling) and product development.
Sometimes we may need to retain your data for longer, for
example if we are representing you or defending ourselves in
a legal dispute or as required by law or where evidence
exists that a future claim may occur.

Please contact our Data Privacy Representative if you object
to the use of, or you have any questions relating to the use
of, your data, the retention of your personal data.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

We will transfer your data to third parties based outside the
European Economic Area. This is necessary for the purposes of
administering out business and underwriting and claims
processing purposes. Such parties are not permitted to use
your personal data for any other purpose than for what has
been agreed with us. These parties are also required to
safeguard your personal data through the use of appropriate
technical and organisational data security measures and are
prohibited from disclosing or sharing your data with other
third parties without our prior authorisation, or unless as
required by law.

Please contact our Data Privacy Representative for a list of
countries and organisations your personal data is transferred
to and/or for further information on the measures undertaken
to safeguard your data.

YOUR RIGHTS

Individuals are provided with legal rights governing the use
of their personal data. These grant individuals the right to
understand what personal data relating to them is held, for
what purpose, how it is collected and used, with whom it is
shared, where it is located, to object to its processing, to
have the data corrected if inaccurate, to take copies of the
data and to place restrictions on its processing. Individuals
can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data
Protection Act 2018. The following list details these rights:
The right to be informed about the personal data being
processed;
The right of access to your personal data;
The right to object to the processing of your personal data;
The right to restrict the processing of your personal data;
The right to rectification of your personal data;
The right to erasure of your personal data;
The right to data portability (to receive an electronic copy
of your personal data);

Rights relating to automated decision making including
profiling.

Individuals can exercise their Individual Rights at any time.
As mandated by law we will not charge a fee to process these
requests, however if your request is considered to be
repetitive, wholly unfounded and/or excessive, we are
entitled to charge a reasonable administration fee.

In exercising your Individual Rights, you should understand
that in some situations we may be unable to fully meet your
request, for example if you make a request for us to delete
all your personal data, we may be required to retain some
data for taxation, prevention of crime and for regulatory and
other statutory purposes.

You should understand that when exercising your rights, a
substantial public or vital interest may take precedence over
any request you make. In addition, where these interests
apply, we are required by law to grant access to this data
for law enforcement, legal and/or health related matters.

The flow of data within this business sector is complex and
we ask you to keep this in mind when exercising your ‘rights
of access’ to your information. Where we may be reliant on
other organisations to help satisfy your request this may
impact on timescales.

If you require further information on your Individual Rights
or you wish to exercise your Individual Rights, please
contact our Data Privacy Representative by e-mailing
HYPERLINK "mailto:admin@momentumwarranties.co.uk"
admin@momentumwarranties.co.uk or by writing to Momentum
Warranties Ltd, King James VI Business Centre, Friarton Road,
Perth, PH2 8DY.

PROTECTING YOUR DATA

We will take all appropriate technical and organisational
steps to protect the confidentiality, integrity, availability
and authenticity of your data, including when sharing your
data within our firm and authorised third parties.

DATA PRIVACY REPRESENTATIVE

To ensure data privacy and protection has appropriate focus
within our organisation we have a Data Privacy Representative
who reports to our senior management team. The Data Privacy
Representative’s contact details are as follows: The Data
Privacy Representative, Momentum Warranties Ltd, King James
VI Business Centre, Friarton Road, Perth, PH2 8DY or email
HYPERLINK "mailto:admin@momentumwarranties.co.uk"
admin@momentumwarranties.co.uk or by telephoning 0330 445
0059.

COMPLAINTS

If you are dissatisfied with any aspect of the way in which
we process your personal data please contact our Data Privacy
Representative. You also have the right to complain to the
UK’s data protection supervisory authority, the Information
Commissioner’s Office(ICO). The ICO may be contacted via its
website which is HYPERLINK "https://ico.org.uk/concerns/"
https://ico.org.uk/concerns/, by HYPERLINK "https://
ico.org.uk/global/contact-us/live-chat" live chat or by
calling their helpline on 0303 123 1113.

HOW TO CONTACT US

If you have any questions regarding this Notice, the use of
your data and your Individual Rights please contact our Data
Privacy Representative, Momentum Warranties Ltd, King James
VI Business Centre, Friarton Road, Perth, PH2 8DY or by emailing
admin@mometumwarranties.co.uk or by telephoning 0330
445 0059.