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”).
Definitions and interpretation
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;
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;
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;
the website www.joinspring.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
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 firstname.lastname@example.org.
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 email@example.com or telephoning 0161 428 1212. Shepherds Friendly’s data protection officer is Tim Robertson.
We may collect the following Data, which includes personal Data (as defined in the Data Protection Laws), from you:
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:
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
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:
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:
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: firstname.lastname@example.org.
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.
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.
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: email@example.com, , 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
Changes of business ownership and control - Spring
The following section does not relate to Data processed in connection with Income Protection Products.
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 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.
You may contact Spring Financial LTD by email at firstname.lastname@example.org.
This policy was last updated on October 2020.