Privacy Policy

About us

Abbeygate Insurance Brokers LTD, Sucursal em Portugal ("Abbeygate Insurance") is committed to protecting the privacy and confidentiality of all individuals. We abide by the rules of the General Data Protection Regulation (GDPR) and are authorised and regulated by the Autoridade de Supervisão de Seguros e Fundos de Pensões (ASF) to advise on and/or arrange insurance products. This includes processing any personal data lawfully, fairly and in a transparent manner.

What information do we collect about you, and why?

As a brokerage and as part of our service we will only collect information from you so that we can advise on and arrange products that may be suitable for you. In the financial services industry we call this fact-finding — it provides us with the information we need to recommend a product that meets your circumstances and requirements.

When obtaining information from you we will do so by phone, email or post, and will confirm the accuracy of the data collated. It is important that all the data we hold on you is accurate so that we can advise on and arrange suitable products.

The types of information we collect include: contact details, occupation, income and expenditure, credit details, insurance requirements, existing policies, bank details. In addition, we may collect sensitive personal data such as medical conditions or criminal offence data where required to arrange a policy on your behalf.

Contact details received from a third-party lead generator

Occasionally we may receive your contact details from a third-party lead generator to whom you have expressed an interest in the products or services we offer. Where we use lead generators we require that they have obtained your consent and have made it clear that they will pass your details on to a firm such as ours, and that you will be expecting us to contact you.

Information from other sources

We may obtain information from other sources, such as public records, if required. This is to enable us to verify who you are or facts that you have told us are accurate.

How will we use this information?

We will only use your data in ways that you would reasonably expect us to. We use the information to research the market on your behalf, prepare a personalised quotation, arrange the policy with the chosen insurer, contact you at renewal or review, assist with claims or complaints, and (with your consent) keep you informed of new products or offers. Telephone calls may be monitored and/or recorded for training purposes and complaint handling. Where we record the call you will be informed.

The lawful basis on which we use this information

We process your data using the lawful basis of "legitimate interests" — the most suitable basis under GDPR for arranging insurance policies, and consistent with ASF rules.

Who will it be shared with?

If you proceed to take out a policy then we will pass your details to the insurer the policy will be arranged with. If you wish to use a credit facility to pay for your insurance, we may provide Close Brothers Finance with your details and arrange payment through them. Where we assist with a claim we will liaise with the insurer and the loss adjuster appointed to your case.

Where required we may forward your details to regulatory authorities or fraud agencies where we have a legal obligation to do so.

Security of personal information

We will not share any of the information you provide with third parties for marketing purposes, or store any of your information outside of the European Economic Area. The information you provide will be held securely by us regardless of whether the information is in electronic or physical format. We use leading technologies and security measures to safeguard your information.

How long will we retain your data?

We will only hold data for no longer than is necessary. Where we have arranged a policy on your behalf we will keep your file (including personal data and any call recording) on record for a minimum of six years, in line with our regulatory obligations with ASF.

Your rights

You have the right to:

• Be informed about how we use, share and store your personal information;
• Request access to the personal data we hold on you (a Subject Access Request) — we will respond promptly and within one month;
• Request your personal data is amended if inaccurate or incomplete;
• Request your personal data is erased where there is no compelling reason for its continued processing;
• Request that the processing of your data is restricted;
• Object to your personal data being processed;
• Rights in relation to automated decision-making and profiling (we do not use these systems).

Where the processing of your data is based on your consent, you have the right to withdraw this consent at any time by contacting us by phone or email.

Marketing

Where we need your consent we will ask for it separately — no pre-ticked boxes. Your consent must be freely given by positively opting in. You may withdraw your consent at any time by contacting us by email or phone. Where consent is obtained, we will record what you have consented to, the time and date, and how consent was obtained.

Right to complain

If you are unhappy with the way we have used your data, please notify Andrew Francis using the contact details below. You may also raise data-protection concerns directly with the Comissão Nacional de Protecção de Dados (CNPD) — www.cnpd.pt.

How to contact us