Privacy and 
Fair Processing Notice

Axiiem is a trading name of Digital Portfolio Solutions Limited. This notice explains who we are, the types of information we hold, how we use it, who we share it with and how long we keep it. It also informs you of certain rights you have regarding your personal information under current data protection law. In this notice, “we”, “us” and “Axiiem” mean Digital Portfolio Solutions Limited. The terms used in this Privacy and Fair Processing Notice are based on those provided by the Information Commissioner’s Office. You can find out more about the ICO here: https://ico.org.uk/.

Who are we?

Axiiem is a trading name of Digital Portfolio Solutions Limited, which is the controller responsible for deciding how your personal data is processed under this notice. Digital Portfolio Solutions Limited (company number 02774470). The registered office for this entity is Mezzanine Floor, 75 King William Street, London, England, EC4N 7BE.

We are registered with the Information Commissioner’s Office for the products and services we provide to you.

Please see our ICO registration details here: https://ico.org.uk/ESDWebPages/Entry/Z8373532

You can contact us for general data protection queries by email to:

dataqueries@digitalportfoliosolutions.co.uk or in writing to the Data Protection Officer, Digital Portfolio Solutions Limited, 2 Minster Court, Mincing Lane, London EC3R 7PD.

Please advise us of as much detail as possible to help us comply with your request. Where other companies in the Ardonagh Group process personal data on our behalf or receive it as part of the services we provide, we will identify those disclosures in this notice.

What information do we collect? 

To enable us to provide you with the right product or service to meet your needs (or to handle a claim on your behalf), we will collect and process personal information which may include, but not necessarily be limited to, your name, address, telephone number, email address, occupation, date of birth, additional details of risks related to your enquiry or product, and payment details (including bank account number and sort code).

Data Protection law says that we can use personal information only if we have a lawful basis for doing so. Our lawful basis will depend on the type of personal data collected and the purpose for which we are processing it. Where we process your personal data, one of the following lawful bases will apply:

We may have a business or commercial reason of our own to use the personal data we have collected, this is known as a ‘legitimate interest’ for processing. Where we rely on legitimate interest, we will always undertake a balancing test to ensure that our interests are not outweighed by your personal interests or fundamental rights and freedoms which require protection.

We may need to request, collect and process additional sensitive personal information such as, but not limited to, details of convictions or medical history for us to provide you with the product or service or to process a claim. Data Protection Law treats this as highly sensitive personal data.

We won’t collect or use these types of personal information unless completely necessary. If we do, it will only be:

If you object to our processing of your personal data, we may be unable to offer you a product or service.

How do we use your personal information? 

We will use your personal information to:

We may also take the opportunity to: 

From time to time, we will need to call you for a variety of reasons relating to your products or service (for example, to update you on the progress of a claim or to discuss renewal of your insurance contract). To ensure the confidentiality and security of the information we hold, we may need to request personal information and ask security questions to satisfy ourselves that you are who you say you are. 

We aim to keep the information we may hold about you as accurate as possible, but we depend on your assistance to update the personal information we may hold when necessary. You can inform us of a change in your details by contacting your account handler or claims contact at any time.  

We may aggregate information and statistics on website usage or for developing new and existing products and services, and we may also provide this information to third parties. These statistics will not include information that can be used to identify any individual. 

Automated Decision Making

We may use automated decision-making in processing your personal information for some services and products. This may include using artificial intelligence (AI) tools to help us improve the products and services we provide to you and to make our internal processes more efficient. We rely on legitimate interests under the UK GDPR to use AI in this way.

Personal data processed through our AI tools is retained in line with our standard data retention schedule. We do not retain data for longer than is necessary for the purpose for which it was processed.

Securing your personal information  

We follow strict security procedures in the storage and disclosure of your personal information in line with industry practices, including storage in electronic and paper formats. 

We store all the information that you provide to us, including information provided via forms you may complete on our websites, and information which we may collect from your browsing (such as clicks and page views on our websites). 

Any new information you provide us may be used to update an existing record we hold for you.  

When do we share your information? 

The insurance lifecycle involves the sharing of your personal data between insurance market participants such as insurers or loss adjusters, some of whom you will not have direct contact with. In these instances, while the information you provide will be disclosed to these companies, it will only be disclosed by Digital Portfolio Solutions Limited to allow for the provision and administration of the service provided (for example verification of any quote given to you, claims processing, underwriting and pricing purposes, or to maintain management information for analysis).  

To help us prevent financial crime, your details may be submitted to fraud prevention agencies and other organisations where your records may be searched, including the Claims and Underwriting Exchange (CUE) and the Motor Insurers Anti-Fraud and Theft Register (MIAFTR). 

We may also share your information with anyone you have authorised to deal with us on your behalf. 

If we provide information to a third party, we will require it and any of its agents and/or suppliers to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy and Fair Processing Notice or an equivalent Notice or Policy. 

We may also need to pass your personal data to other companies in the Ardonagh Group where they provide shared services, IT, management information, referrals support or other operational support connected with the products or services we provide.

We will not share your personal information for third party marketing or for any other purposes without your consent unless required by law to pass on your information to the police or other law enforcement body, or statutory or regulatory authority, including but not limited to the Employer’s Liability Tracing Office (ELTO) and the Motor Insurance Bureau (MIB). 

Sometimes we need to transfer your personal information to, store it in, or access it from a location outside the United Kingdom. This can happen when we use service providers based overseas (for example, for IT, hosting, claims handling or analytics), when insurers, reinsurers or other parties in the insurance market we work with are based outside the UK, or when other companies in the Ardonagh Group that support our operations are located in another country.

Whenever we transfer your information outside the UK, we make sure it is properly protected. We only transfer data to countries that the UK Government has confirmed offer an adequate level of protection, or we put in place an approved data protection contract such as the UK International Data Transfer Agreement or the UK Addendum to the Standard Contractual Clauses with the organisation receiving the data. In some cases, other safeguards approved under UK data protection law may apply. We also assess the risks of each transfer where needed and use technical measures, such as encryption and access controls, to keep your information secure.

If you would like to know more about the countries your data may be transferred to, or to see a copy of the safeguards we use, please contact our Data Protection Officer using the details in the “Who are we?” section.

How long do we keep your information for? 

We will not keep your personal information longer than is necessary for the purpose for which it was originally provided unless we are required by law or have other legitimate reasons to keep it for longer (for example if necessary for any legal or claims proceedings).  

We will normally keep information for no more than 7 years after termination or cancellation of a product, contract, or service we provide. In certain cases, we will keep your information for longer, particularly where a product includes liability insurances or types of insurance for which a claim could potentially be made by you or a third party at a future date, even after your contract with us has ended.   

Children’s Data

We do not and will not knowingly collect information from any unsupervised child under the age of 16. If you are under the age of 16, you may not use our sites unless your parent or guardian has provided us with their consent for your use of our sites.

Cookies and Tracking Data

We may use cookies and similar tracking technologies on our websites and apps, and in emails we send you.

Cookies are small computer files that get sent to your computer, tablet or mobile device by websites when you visit them. They stay on your device and get sent back to the website they came from when you go there again. Cookies store information about your visits to that website, such as your choices and other details. Some of this data does not have personal details about you or your business, it is still protected by this Privacy Notice.

Your rights 

Under GDPR you have the right to change or withdraw your consent and your rights also include: 

Your right of access – You have the right to ask us for copies of your personal information.  

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.  

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.  

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.  

Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances. 

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. 

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you, unless we tell you we are entitled to a longer period under applicable data protection law.

How to complain  

If you are not satisfied with our use of your personal data or our response to any request made by you to exercise any of your rights, or if you think that we have breached the GDPR, then you have the right to complain to us using the below contact details:

E-mail: dataqueries@digitalportfoliosolutions.co.uk

Post: F.A.O: Data Protection Officer, Digital Portfolio Solutions Limited, 2 Minster Court, Mincing Lane, London EC3R 7PD.

Complaints will be acknowledged within 30 days.

Should you wish to review, amend, or transfer any of the personal data we hold on you, please contact our Data Protection Officer at the earliest opportunity.

Should you remain dissatisfied, you have the right to complain to the ICO. Further details of your rights and your right to complain to the ICO can be obtained by visiting the ICO website at https://ico.org.uk/.   

Updates 

We are required by law to change or update this Privacy and Fair Processing Notice to keep it accurate and current.