Privacy Policy

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:

  1. Customers purchase Products and Services, or sign up to Insurance Club;
  2. users access the Website;
  3. users complete Insurance Club tasks;
  4. and/or individuals otherwise provide personal information to Spring Financial LTD (together the “Data”).

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:

  1. the singular includes the plural and vice versa;
  2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
  3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
  4. “including” is understood to mean “including without limitation”;
  5. reference to any statutory provision includes any modification or amendment of it;
  6. the headings and sub-headings do not form part of this privacy policy.

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:

  1. except for the Data that relates to the provision and administration of Income Insurance Products (as further described below), Spring Financial LTD is the “data controller”, (meaning the organisation that determines the purposes for which, and the manner in which, your data is processed), this shall include where Spring Financial LTD processes Data to meet its own regulatory obligations and to undertake marketing activities; and
  2. for the Data that relates to the Income Insurance Products in respect to the provision, administration, claim handling of such policies and any other activities that could reasonably be considered to relate to the provision or distribution of the Income Insurance Products, Shepherds Friendly is the data controller and we, Spring Financial LTD, act as their data processor.

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:

  1. name*;
  2. date of birth / age*;
  3. gender*;
  4. job title*;
  5. profession and employment details*;
  6. contact Information such as email addresses and telephone numbers*;
  7. demographic information such as address (including postcode)*, preferences and interests;
  8. nationality*;
  9. health information, such as medical history*;
  10. financial information such as credit / debit card numbers*;
  11. IP address (automatically collected);
  12. web browser type and version (automatically collected);
  13. operating system (automatically collected);
  14. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
  15. your responses and engagement with Insurance club tasks

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:

  1. data is given to us by you; and
  2. data is collected automatically.

Data that is given to us by you

Spring Financial LTD will collect your Data in a number of ways, for example:

  1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
  2. when you register with us to apply for Products and Services;
  3. when you make a claim under or conduct any other administration activity through us in relation to Products and Services;
  4. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
  5. when you enter a competition or promotion through a social media channel;
  6. when you elect to receive marketing communications from us;
  7. when you use our services;
  8. when you complete tasks under Insurance Club

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

  1. internal record keeping;
  2. improvement of our Products and Services;
  3. transmission by email of marketing materials that may be of interest to you;
  4. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;

in each case, in accordance with this privacy policy.

  1. We may use your Data for the purposes listed in points 1 and 2 above if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
  2. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in: soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services) and where you haven’t subsequently opted-out of receiving communications. Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
  3. For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
  4. If you are not satisfied about our approach to marketing (or we are processing your Data in any other circumstances on the basis of your consent), you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
  5. When you register with us and set up an account to receive Products and Services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

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:

  1. to provide Income Insurance Product;
  2. to handle any claims or related notifications in connection with Income Insurance Product;
  3. to respond to any enquiry or Customer communication in connection with Income Insurance Product;
  4. to meet Shepherds Friendly’s regulatory obligations;
  5. transmission by email of marketing materials that may be of interest to you; and
  6. any other activities that could reasonably be considered to relate to the provision or distribution of Shepherds Friendly Income Protection Policies,

and in each case, in accordance with this privacy policy.

Shepherds Friendly will use your Data for the above purposes where:/p>

  1. the processing is necessary for its legitimate interests as a business and provider of insurance services, for example to allow you to apply for one of its policies, to allow you to make a complaint about its services or to allow it to maintain accurate customer records;
  2. the processing is necessary to comply with a legal obligation, for example anti-money laundering legislation, the requirements of the Financial Conduct Authority and the Prudential Regulation Authority, or those of HMRC;
  3. other processing of personal Data (i.e.in the context of marketing by Shepherds Friendly (or Spring, on behalf of Shepherds Friendly) with your consent; or
  4. for the performance of a contract between you and Shepherds Friendly and the provision of its Products and Services to you.

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:

  1. Shepherds Friendly’s service providers and professional advisers (actuarial services, auditor services, business partners, reinsurers, support services, trained medical professionals and medical support services (should you apply for one of Shepherds Friendly’s protection plans) and other third parties where required or permitted by law, or with your consent);
  2. credit reference or identity verification services and disclosure services.
  3. regulatory and governmental bodies including the Financial Conduct Authority and the Prudential Regulation Authority, HMRC and law enforcement authorities.

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:

  1. access to your account is controlled by a password and a user name that is unique to you.
  2. we store your Data on secure servers.
  3. payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology).

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:

  1. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
  2. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
  3. Right to erase – the right to request that we delete or remove your Data from our systems.
  4. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
  5. Right to data portability – the right to request that we move, copy or transfer your Data.
  6. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
  7. Right to be informed – the right to be informed about the processing of your Data including any automated decision-making and profiling.

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.