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Commercial Experts Privacy Policy

Summary

Below is a summary of some key terms set out within this Privacy Policy. We are committed to protecting your personal information when you use our site and we want you to be confident that your personal information is safe and secure with us. This Privacy Policy explains how we use your personal information including the following:

What personal information do we collect
How we use the personal information which is gathered
Whom your personal information is shared with;
How we communicate with you; and
Your rights and choices you have when it comes to your personal information

Use of our Site is subject to the terms of this Privacy Policy and our Terms and Conditions. If you do not agree to these terms, please stop using our Site / Services immediately.

We process your personal data in order to provide you with the service that you have applied for using our site. We act as a credit broker where your application will be shared with our panel of broers, and business insurance providers. See "How do we use your personal information" for further details.

This Privacy Policy may change occasionally, so please check this page when using our site to ensure that you are happy with any changes.

If you wish to make an enquiry or exercise any of your rights as set out in this Privacy Policy, please contact our Compliance Department here

Who Are We?

insurance-commercialexperts.co.uk is a trading name of trading style of TFLI (US) INC who is an Appointed Representative of TFLI Limited who effects introductions and is not a direct provider and is entered on the Financial Services Register under reference number: 723630. TFLI (US) INC is authorised and regulated by the Financial Conduct Authority and is entered on the Financial Services Register under reference number: 946605.

TFLI (US) INC is registered in the United States of America (Company number P20000059850). Registered Office: 1200 Brickell Avenue Suite 1950 #1016. Miami, FL 33131. Licenced by the Information Commissioner's Office, Registration Number ZB053626).

TFLI (US) INC is a controller in relation to the processing of personal information that is provided when you complete our application. If you want to contact our data protection officer or you have any data protection questions, please contact our Compliance Department here

How do we collect information from you and where from?

From you - personal information we collect will be directly from you when you use the site to submit an application. We will collect the information from you via our websites, mobile applications, or other similar devices or applications operated by or on behalf of TFLI US INC an Appointed Representative of TFLI Limited.

The data we collect when you use our site to make an application includes, but is not limited to, your: name, company name, mobile number, email address, postcode, business sector, number of employees, IP address and device type.

We do not collect any personal information from children, or about children, nor do we collect any sensitive or special category data.

In the course of finding, you an insurance provider, we may store information about how you use our site, for example, the pages viewed, the platform from which you came to visit our site and the application completion.

We may monitor or record your calls, emails, SMS or other communications but we will do so in accordance with data protection legislation and other applicable laws. Monitoring or recording will always be for business purposes, such as for quality assurance and training (for example where calls or emails have been sent to our customer service department) to enable us to deliver our services.

Note that it is your responsibility to check and ensure that all information, content, material or data you provide on this site is correct, complete, accurate, and not misleading and that you disclose all relevant facts.

How Do We Use Your Data?

to enable you to access and use the services;
passing it to our trusted partners including companies whose products or services are included on our site, with a view to them providing you with an online or telephone quote for the insurance requested by you. When our trusted partners use your data to provide a quote they will act as data controllers of your data - you can see a list of our partners in section 5
to process an application between you and a third party such as the broker and business insurance provider.
to communicate with you at your request to offer help and support and to resolve any Service issues.
to communicate with you, including some or all of the following:
to track sales, which may involve us sharing data with your product provider relating to the product(s) you have purchased. Your product provider may also send us information they hold relating to the product(s) you have purchased for this purpose;
to circulate our customer survey review which is available to customers once an application has been completed;
to send you marketing messages regarding financial service products such as invoice finance and business loans or similar products or services.

Keeping you informed about our services: where you agree that we will contact you via email and/or SMS, in relation to our similar financial products such as invoice finance and business loans that may interest you.

Whenever you provide us with personal information, where necessary we will seek your consent and/or we will give you an opportunity to tell us you do not consent to the use and sharing of your information for marketing purposes. Unless you tell us otherwise, you are consenting to such use.

You can withdraw your consent to us and our panel of business insurance providers and brokers processing your personal data for the purposes of the application at any time by clicking the "unsubscribe" option in any SMS, Email, or within the communications sent by partners. You can also email us here

Who Do We Share Your Personal Information With?

When you complete an application, you consent to us disclosing your personal information to the following parties:

insurance-commercialexperts.co.uk and TFLI (US) INC: (i) to communicate with you, including sending you information about products and services which may be of interest to you; (ii) to speed up form filling, or to personalise, or improve your experience on its website, mobile applications or other similar devices, channels or applications; or (iii) in accordance with its privacy policy.
TFLI Limited who act as a broker who will process your insurance application and share your personal data with their panel of Brokers, and Insurance Providers listed below in the Trusted Third Parties section, you can also view details of how they will process your personal data within their privacy policies.
Panel of Brokers / Business Insurance providers as detailed below. They will contact you directly with regards to your insurance application:
the Financial Conduct Authority and/or other regulatory/governing bodies, for the purposes of compliance monitoring;
Google, Linkedin, Facebook to enhance targeting/exclusions from advertising.
Credit Reference Agencies and Other Agencies where we collect your data and share with organisations where they have a lawful reason, which will include these organisations' own legitimate interests. The data will be used to trace individuals, verification and/or validation of the identity of individuals for the purpose of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.
Under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn't outweighed by the effects it will have on the relevant individuals. On that basis, we may pass your data to organisations who may combine it with data from other sources, analyse and profile it (such as by predicting information about you), and pass their knowledge on to other companies to help trace you to provide important information or return assets to you. Your data may also be used in a similar manner to aid debt recovery and to prevent fraud by helping to identify you (for instance when you are applying for new products). Organisations to support the assessment of credit risk, pricing and affordable payments. If you do not wish for your data to be used this way by these organisations for this purpose then please email us here or refer to this policy.

Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account:

if required or permitted to do so by law;
if required to do so by any court, the Financial Conduct Authority, the Competition and Markets Authority or any other applicable regulatory, compliance, Governmental or law enforcement agency;
if necessary, in connection with legal proceedings or potential legal proceedings; and/or
in connection with the sale or potential sale of all or part of our business.
Google, Linkedin, Facebook to enhance targeting/exclusions from advertising.
TFLI (US) INC collect your data and will share it for commercial gain with third parties. These organisations will have a relationship with you or it may be used where they have a lawful reason, which may include these organisation's own legitimate interest. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.

You can object to us processing your data in this way by contacting our Compliance Department here or using the contact details stated in section 8. In addition

FRAUD PREVENTION AGENCIES (FPA'S)

If we reasonably believe false or inaccurate information has been provided, including in relation to a person's identity, and fraud is suspected, details, including personal data may be passed to fraud prevention agencies to prevent fraud and money laundering.

Your details may be passed to statutory bodies, regulators, legal bodies, credit reference agencies, fraud prevention entities and identity and address verification agencies who may record and use your details. They may also disclose your information to other organisations for credit reference, debt tracing, and fraud and money laundering prevention purposes. If you have any queries regarding these uses, please contact the relevant organisation.

By submitting an application form on our site, you confirm that all of the information provided is true and accurate. You also, when applying, authorise the broker or business insurance provider to use both fraud prevention and credit referencing agencies to help make relevant decisions. Credit checks and credit reference agencies can also help prevent fraudulent applications.

What Is a Fraud Prevention Agency?

Fraud Prevention agencies (FPA) collect, maintain and share information on any known or suspected fraudulent activity.

They work in the following ways with various organisations:

If false or inaccurate information is provided and fraud is identified, details will be passed to Fraud Prevention Agencies
Law enforcement agencies may access and use this information.
FPA's along with ourselves and other organisations, may also access and use this information to prevent fraud and money laundering, for example, when:
Checking details on applications for credit and credit-related accounts, or other, facilities;
Managing credit and credit-related accounts or other facilities;
Recovering debt;
Checking details on proposals and claims for all types of insurance; and,
Checking details of job applicants and employees.
We, and other organisations may also access and use the information recorded by FPAs from other countries.

You have the right to object to this processing at any time by contacting us here

How We and Our Partners May Contact You as Part of Your Application?

We, and our panel of brokers, and business insurance providers will keep you informed about the progress of your application. Unless you state otherwise you may be contacted via telephone, email and SMS. (See further section on 'How we keep you informed)

Lawful basis for collecting your personal information

We rely upon a different lawful basis to process your personal data according to the reason for which you have provided your data to us.

Our use of your personal data will always have a lawful basis.

Consent:

When you submit your application with TFLI (US) INC who is an Appointed Representative of TFLI Limited, we process your personal data on the basis that you have provided your consent to be contacted by TFLI (US) INC who is an Appointed Representative of TFLI Limited, our panel of business insurance providers and brokers in relation to your application.

Alternatively, you can withdraw your consent by contacting our Compliance Department here or using the contact details stated in section 8. If you change your mind about agreeing to us processing your personal data, this will not have any effect on the lawfulness of any processing we have carried out before you changed your mind.

Contract:

Your personal data will also be processed on the basis that we need this information to fulfil our obligations under the contract we have entered into with you by providing you with a insurance quote. TFLI (US) INC who is an Appointed Representative of TFLI Limited, our panel of business insurance providers and brokers will contact you regarding your application.

You can object to us processing your data in this way by contacting our Compliance Department here or using the contact details stated in section 8. In addition, if you object to your personal information being used in this way you should stop using our site/services immediately.

Legitimate Interest:

We have a legitimate interest in processing your data (i.e. to share your application with our panel of business insurance providers and brokers to obtain the insurance service you have applied for.

It also includes processing your data for tracing, verification and validation of identity. Tracing could take place for the purpose's debt collection fraud prevention and anti-money laundering processes and asset reunification. Checking of individual identities. Age verification and authentication. Individual reference or lookup services. Know you customer due diligence services.

You can object to us processing your data in this way by contacting our Compliance Department here or using the contact details stated in section 8. In addition, if you object to your personal information being used in this way you should stop using our site/services immediately.

How You Contact Us

If you are required to telephone us using the specified telephone numbers on our website under the Contact or advertising/marketing correspondence then your call may be recorded for training, quality and regulatory purposes.

You can also contact us by sending an email us here

We pride ourselves in complete customer care and this gives us the opportunity to continuously improve and monitor our customer experience.

How We Keep You Informed

We may want to make contact with you at some point in order to keep you informed regarding offers on products or services which we think you may find of interest; this contact will be made via email and SMS. Third parties may also wish to contact you from the information we have shared with them regarding the insurance application, any information that is shared to third parties is completely trusted for the purpose it is specified for, third parties may also use the same means of contact stated above.

What Marketing Communications will I receive?

Soft opt-in is an exception to the general requirement to obtain consent before sending direct marketing to you by electronic means (such as email or text message for example) and applies where you have previously engaged with us (for example by submitting your contact details on our website to make an enquiry about Our Service), and we are marketing our similar products and services. Under the 'soft opt-in', we will assume you still want to hear about our other related products and services until you opt out or unsubscribe. For most customers, this is beneficial as it allows us to tell you about our other similar products services that we think would be useful to you alongside the specific one you originally expressed an interest in.

Unless the customer states otherwise we will contact you via means of SMS and Email to provide marketing communications and alerts relating to our services and our associate products where you have consented to be contacted.

You can withdraw your consent within the application process within the opt-in statement where you can confirm your contact preferences. In addition, you can withdraw your consent at any time by clicking the "unsubscribe" option in any SMS, Email, or by emailing us here.

Ensuring your personal details & or preferences are kept up to date.

It is your responsibility to ensure that any information we have on record for you is kept up to date-and correct. If you do require any of your information to be updated then please contact us as soon as possible so we can ensure it is corrected.

If you require your preferences to be updated then please contact our Compliance Department as soon as possible here

Who Might Our Panel of Brokers/Business Insurance Providers Share Your Personal Information with?

Some of our providers will use your personal information to assess your circumstances (including information about any third party who is named on the application) and verify the information that you have provided before providing an insurance quote to you. Some providers may carry out checks with fraud prevention and credit reference agencies. Both public data (e.g. the electoral roll) and private data (e.g. your personal credit history) may be checked in this way.

Some providers may carry out checks against data they already hold on you, (or is held by the company whose brand they administer the product for, or members of their group of companies) such as data from existing products, account data, data from previous product transactions, accounts you may hold with them to determine your insurance product. If providers carry out these searches, a record of the search will appear on your credit report. Some providers may also check public and private higher education sources to obtain information about your educational background.

This information exchange allows providers to verify the information that is provided during the quote process (including information about any third party who is named on the policy) and also helps to detect fraudulent applications. These checks are not unique to users of our Services - they may also be carried out if you obtain quotes from other sources.

If you decide to take out an insurance product, the information you have provided to us, together with any further information requested by, and supplied by you or us to the third-party provider, will be held by the provider for the purposes set out in that provider's privacy policy. Therefore, you are strongly advised to read your chosen provider's privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the financial agreement.

How Secure Is Our Site and What Steps Do We Take to Keep Your Personal Information Safe?

Our Sites are "Let's Encrypt Secure Websites" and keeping information about you secure is very important to us. However, no data transmission over the internet can be guaranteed to be totally secure. Sensitive information, for example, your card details, is encrypted to minimise the risk of interception during transit.

We do our best to keep the information you disclose to us secure. However, we can't guarantee or warrant the security of any information which you send to us, and you do so at your own risk. By using our Sites you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

Where will your personal data be held?

Your personal data may be held within the European Economic Area (EEA) or outside the EEA. If any personal data is transferred or stored outside of the EEA, we check whether the EU Commission has determined that it will afforded the same level of protection as it would within the EEA (this is called an adequacy decision). If it will not, we will ensure any such transfer is subject to appropriate safeguards (for example by putting appropriate contractual provisions in place with relevant third parties to provide us with reassurance about the security of your personal data) or is otherwise permitted (for example with your express consent to transfer) in accordance with the provisions of the GDPR.

Rights of Access to Your Personal Information

You have certain rights under the General Data Protection Regulations. For example, we will always let you have a copy of the personal information we hold about you if you request it from us in writing.

Right to be informed when we collect your data, we have to tell you what we are going to do with it primarily through this Privacy Policy and within the opt-in/consent statement.
Right to Object - because you have asked us to help you find an insurance product or service, we need to process the personal information you give us to enable us to find the best product or service available amongst our panel of business insurance providers, and Brokers. You can object to this processing at any time by sending us an email here. We will action any request you make promptly, although this will mean that we will not be able to help you find the insurance product or service that you asked us to search for.
Right of Access - you can ask us at any time to confirm whether we hold your personal information, and if so, you can access it by emailing us here at: Compliance Department.
Right to rectification - if we hold personal information about you that is inaccurate, you can ask us to correct it, and we will do this as quickly as possible.
Right to erasure - if it is no longer necessary for us to hold your personal information bearing in mind the reason why you provided it to us, you can ask us to delete it. If you ask us to do this, we will delete your personal information as soon as possible although this will mean that we may not be able to help you find the insurance product or service that you asked us to search for.
Right to restrict our use of your information - you can ask us to restrict our processing of your personal information if you think for example that the personal information you gave us is inaccurate. This may mean that we may not be able to help you find the insurance product or service that you asked us to search for.
Right to data portability - this gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly be used if you were switching banks, insurance companies and utility companies.
Right related to automated decision-making including profiling - You have a right to object to automated decision making, to express your point of view, ask for human intervention, and to be provided with an explanation of the decision with your option to challenge it. You can request this by emailing us here
Right to complain to the Information Commissioner's Office (ICO) - we will try to resolve any complaint that you may have in relation to data protection issues. If you are not happy with our final response you have the right to have your complaint dealt with by the ICO. Please refer to our Complaints section How To Make a Complaint below for further information.

To make enquiries and/or exercise any of your rights set out in this Privacy Policy please contact our Customer Services Team here

How Long Will We Retain Your Personal Information For?

The amount of time we retain your information will depend on the reason it was provided:

If you request to opt out of marketing, we will still need to retain your information in order to evidence your preferences.
We will need to retain, for a minimum period of 6 years, any information relating to applications you have entered into on our website. This period will commence once your relationship with us has ended. We need to keep your information for this length of time to assist with any potential future complaints.
Your information/data will not be used for marketing purposes once 12 months have passed following your application.

If you require further information on our data retention policies, please click here

Right to Opt-Out of Future Contact from Us and Our Trusted Third Parties

You can opt out of future contact from Commercial Experts at any time. During the application process, you can opt out of future contact within the opt-in statement application page. All of our marketing messages provide an opt-out link - please allow up to 48 hours for us to process your opt-out request. Alternatively, you can email us here where your details will be removed from any future marketing campaigns.

If you are receiving contact from third parties you will need to contact them directly and request them to remove your details.

Your Right to be Forgotten / Erasure of Your Personal Information

Under the General Data Protection Regulation (GDPR), all individuals have the right to request the deletion or removal of personal data (the right to be forgotten) under the following circumstances:

Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
When the individual withdraws consent.
When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
The personal data has to be erased in order to comply with a legal obligation.
The personal data is processed in relation to the offer of information society services to a child.

There are some circumstances where the right "to be forgotten" does not apply i.e. where we need to comply with a legal obligation.

If you wish to request your "right to be forgotten" please click here

Our marketing partners will also be informed of your request where you have stipulated to do so.

How to make a complaint

Commercial Experts always aim to be fair and honest in everything we do, so if you have a complaint about any aspect of our service, we're keen to resolve it as quickly as possible. You can contact us in any of the following ways:

By Post:
Complaints Department, Commercial Experts, TFLI Limited, First Floor Beechwood Court, Springwood Way, Tytherington Business Park, Macclesfield, Cheshire, SK10 2XG

By Telephone: 01625 32 25 55

By Email: here

We will acknowledge receipt of the complaint within 3 working days and we hope to provide a final response within 4 weeks. We will write to you again within 4 weeks if we are unable to provide a final response within that time period. In any event, we will respond to your complaint in full within 8 weeks.

If you are not satisfied with our response, you must send your complaint to the Financial Ombudsman Service within six months of the date of the final response, Contact details for the Financial Ombudsman Service are as follows:

Financial Ombudsman Service
Exchange Tower
London
E14 9SR
Telephone: 0800 023 4567
Web site: www.financial-ombudsman.org.uk

Email: complaint.info@financial-ombudsman.org.uk

You can report any of your concerns to the Information Commissioner's Office (ICO)

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510

Last updated July 2023