This privacy policy sets out how Spring Financial LTD collects, uses and stores personal information (on its own behalf and also on behalf of Shepherds Friendly) and provides details of how you can exercise your rights under Data Protection Laws. Spring Financial LTD and Shepherds Friendly take the privacy of your information very seriously.
Spring Financial LTD collects personal information when:
Shepherds Friendly collects, uses and stores the Data insofar that it is collected in connection with those Products and Services issued by Shepherds Friendly and distributed and administered by Spring Financial LTD (“Income Insurance Products”).
Please read this privacy policy carefully.
Please read this policy in conjunction with our terms of use and cookies policy.
Definitions and interpretation
In this privacy policy, the following definitions are used:
Customer (or you, where applicable)
any individual that enquires about, applies for, or purchases the Products and Services, including any third parties that provide information, or are referred to, as part of the Product and Services application process, and
any individual that enquires about, applies for, or signs up to Insurance Club.
Data Protection Laws
any applicable law relating to the processing of personal Data, including, but not limited to, the GDPR, and, to the extent that they apply, any national implementing laws, regulations and secondary legislation, and any equivalent legislation amending, supplementing or replacing the GDPR;
GDPR
the General Data Protection Regulation (EU) 2016/679;
Products and Services
any products or services marketed, distributed and / or administered by Spring Financial LTD, including any products issued by Shepherds Friendly or a third-party provider;
Shepherds Friendly
The Shepherds Friendly Society Limited, an incorporated friendly society under the 1992 Friendly Societies Act No.240F, authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority (firm reference number 109997) whose registered office is at Hawbank House, 2 High Street, Cheadle, Greater Manchester SK8 1AL;
Spring Financial LTD, we or us
Spring Financial LTD, a company incorporated in England and Wales with registered number 11843942 whose registered office is at 71-75 Shelton Street, Covent Garden, WC2H 9JQ;
Website
the website www.joinspring.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
In this privacy policy, unless the context requires a different interpretation:
Scope of this privacy policy
This privacy policy does not extend to any websites that can be accessed from the Website including, but not limited to, any links we may provide to social media websites.
Data Controller
For purposes of the applicable Data Protection Laws:
You may contact Spring Financial LTD about all issues relating to this privacy notice, your Data and to exercise your rights under Data Protection Laws by sending an email to hello@joinspring.co.uk.
Spring Financial LTD will share communications that relate to Income Insurance Product data with Shepherds Friendly, as data controller. Should you wish to do so, you may also contact Shepherds Friendly directly in relation to Data processed in connection with Income Insurance Products by sending an email to dataprotection@shepherdsfriendly.co.uk or telephoning 0161 428 1212. Shepherds Friendly’s data protection officer is Tim Robertson.
Data collected
We may collect the following Data, which includes personal Data (as defined in the Data Protection Laws), from you:
in each case, in accordance with this privacy policy.
Those items marked with an asterisk are collected by us on behalf of Shepherds Friendly when in connection with an Income Insurance Product.
How we collect Data
We collect Data in the following ways:
Data that is given to us by you
Spring Financial LTD will collect your Data in a number of ways, for example:
in each case, in accordance with this privacy policy.
Data that is collected automatically
To the extent that you access the Website, we will collect your Data automatically, for example, we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
Use of Data
Any or all of the above Data may be required by us, Spring Financial LTD, from time to time in order to provide our Products and Services to you, to process Data on behalf of Shepherds Friendly in connection with the Income Insurance Products (including by administering those Products or handling claims in relation to them) and/or to provide you with the with the best possible service and experience when using our Website.
Use of Data by Spring only
in each case, in accordance with this privacy policy.
Use of Data by Shepherds Friendly (or by Spring on Shepherds Friendly’s behalf)
Any or all of the above Data (marked with an asterisk in the section Data collected) may be required by Shepherds Friendly in order to provide Income Insurance Product to you. Specifically, related Data may be used by Shepherds Friendly for the following reasons:
and in each case, in accordance with this privacy policy.
Shepherds Friendly will use your Data for the above purposes where:/p>
Shepherds Friendly will only process special categories of personal Data (e.g. your medical history) for the specific purpose to which you consented or where it is otherwise permitted to do sounder Data Protection Laws.
Shepherds Friendly may need to share your Data with external companies (i.e. third parties) to help administer your plan and provide Products and Services to you. These third parties include:
Shepherds Friendly may transfer, and store, Data collected from you at a destination outside the UK, and in some instances, to a third country (which shall have the same meaning as in applicable Data Protection Laws). Where this occurs, Shepherds Friendly will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with both the Data Protection Laws and this privacy policy.
Where Spring Financial LTD is processing Data on behalf of Shepherds Friendly in connection with the provision of Income Protection Policies, Spring Financial LTD will share Data with third parties listed above in accordance with the instructions of Shepherds Friendly. This will include the transfer of Data to reinsurers.
Keeping Data secure
We will use technical and organisational measures to safeguard your Data, for example:
Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: hello@joinspring.co.uk.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Data retention
Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Shepherds Friendly will retain your Data for as long as it is necessary for the purposes that it was collected; it will not store your Data for longer than is reasonably necessary or required by law (including any applicable regulatory obligations). By way of example, if you provide your Data and subsequently takeout an Income Protection Policy, then Shepherds Friendly will hold your Data for as long as you hold that policy and for an appropriate period thereafter, to allow Shepherds Friendly, as data controller, to assist with any query or complaint you may have after your policy has ended.
Your rights
You have the following rights in relation to your Data:
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is the legal basis for processing your Data), please contact us via this e-mail address: hello@joinspring.co.uk, , or, in relation to Data processed in connection with Income Protection Products, Shepherds Friendly directly using the contact details set out above.
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us or by Shepherds Friendly, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Our Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
Changes of business ownership and control - Spring
The following section does not relate to Data processed in connection with Income Protection Products.
Spring Financial LTD may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Spring Financial LTD. Data provided by you will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
We may also disclose Data to a prospective purchaser of our business or any part of it.
In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Changes of business ownership and control – Shepherds Friendly
Shepherds Friendly may, from time to time, expand or reduce its business and this may involve the sale and/or the transfer of control of all or part of Shepherds Friendly. Data provided by you related to Income Protection Products will, where it is relevant to any part of the business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to Shepherds Friendly.
Shepherds Friendly may also disclose Data to a prospective purchaser of its business or any part of it.
In the above instances, Shepherds Friendly will take steps with the aim of ensuring your privacy is protected, in accordance with Data Protection Laws.
Changes to this privacy policy
Spring Financial LTD reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted on the Website.
You may contact Spring Financial LTD by email at hello@joinspring.co.uk.
Attribution
This privacy policy was originally based on a document from Rocket Lawyer but has been subsequently amended.
www.rocketlawyer.co.uk
This policy was last updated on October 2020.