Privacy Notice

(also known as "Fair Processing Notice")

Capulus understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website, capulus.co.uk (Our Site) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested when you use our site and services.

  • 1. Information About us

    Our Site is owned and operated by Capulus a limited company registered in England under company number 11274813

    Registered address: Capulus Limited, Britannia House, Van Road, Caerphilly,

    Data Protection Officer: Kevin Smith

    Email address: dpo@capulus.co.uk

    Telephone number: 0333 772 7765,

  • 2. What Does This Policy Cover?

    This Privacy Policy applies only to your use of Our Site and our services. Our Site 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.

  • 3. What Is Personal Data?

    Personal data is defined by the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (the UK GDPR), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 as amended, and any successor legislation) as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

    Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

  • 4. What Are My Rights?

    Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

    a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.

    b) The right to access the personal data we hold about you. Part 11 will tell you how to do this.

    c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.

    d) The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 12 to find out more.

    e) The right to restrict (i.e., prevent) the processing of your personal data.

    f) The right to object to us using your personal data for a particular purpose or purposes.

    g) The right to withdraw consent. This means that, if 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.

    h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

    i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

    For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

    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.

    Further information about your rights can also be obtained from the Information Commissioners Office or your local Citizens Advice Bureau.

    If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 12.

  • 5. What Data Do You Collect and How?

    Depending upon your use of Our Site and Services, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any web analytics daat and we only use cookies necessary for the operation of our site. We do not generally collect any special category or sensitive personal data OR personal data relating to children however we may collect data relating to motoring convictions and/or offences as well as health data in the course of providing insurance services.

    Data Collected How we Collect the Data

    Company and Client contact Data related to contract fulfilment

    While providing Insurance Services Collected from you or your business, from brokers, firms handling claims and finance providers

    Vehicle details

    While providing Insurance services collected from you or your business, or from brokers, firms handling claims and finance providers

    Criminal offence data

    While providing Insurance services collected from you or your business, or from brokers, firms handling claims and finance providers

    Information relating to your lifestyle, finance, health

    While providing Insurance services collected from you or your business, or from brokers, firms handling claims and finance providers

  • 6. How Do You Use My Personal Data?

    Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

    What we Do What Data we Use Lawful Basis

    In providing our products and services we will process company and personal information to allow us to fulfil our contractual obligations

    We use company and personal contact data, details of company and personal offices, company and personal finance details, data relating to motoriing convictions,

    We have a legal basis under for contract fulfilment and the provision of insurance services to collect and process this data

    With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services.

    You will not be sent any unlawful marketing or spam.

    We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

    We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

    We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.

    If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

    In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

  • 7. How Long Will You Keep My Personal Data?

    We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

    Type of Data How Long we Keep It

    Company and personal Information relating to service delivery including, contact data, motoring convictions, health data, finance details and any other information relating to the provision of insurance services

    Until the service period has expired and we are longer required to keep records

    Information relating to the provision of Insurance

    For a minimum of 7 years after the policy has lapsed

  • 8. How and Where Do You Store or Transfer My Personal Data?

    We will only store your data within the UK. This means that it will be fully protected under the Data Protection Legislation.

    Please contact us using the details below in Part 12 for further information about the particular data protection mechanism[s]

    The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:

    • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
    • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioners Office where we are legally required to do so.
  • 9. Do You Share My Personal Data?

    We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].

    To supply insurance services, we will share details with our brokers

    If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

    In some circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  • 10. Can I Withhold Information?

    Our site uses only marketing cookies from third parties and web traffic analytics so we can understand how our visitors use our site. If you wish to opt out some parts of our site will be inaccessible.

  • 11. How Can I Access My Personal Data?

    If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a subject access request.

    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.

    To make this as easy as possible for you, a Subject Access Request Form is 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.

    There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

    We will respond to your subject access request within 28 days and. 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.

    For your security we may require proof of identity, in this case we will contact you to request such proof, the 28-day time for our response to your request will then start from the point that we receive such proof.

  • 12. How Do I Contact You?

    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details

    Data Protection Officer: Kevin Smith

    Email address: dpo@capulus.co.uk

    Telephone number: 0333 772 7765,

    Postal Address: Capulus Limited, Britannia House, Van Road, Caerphilly,

  • Changes to this Privacy Policy

    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up to date.

    This Privacy Policy was last updated on 1/11/2021