Security and privacy notice

This Privacy Notice explains how we use the information we collect about you and how you can exercise your rights. Please read the following carefully as it contains important information relating to the details that you have given us. You should show this notice to any other party related to this insurance.

Our Privacy Notice will be updated from time to time, please check it each time you submit personal information to us or renew your insurance policy. Any update to this Notice will be published on this webpage.

Last Updated May 2023

Who we are

Supersure Insurance is a trading name of The Swift Group, and is arranged and administered by Caravan Guard Ltd. Caravan Guard is authorised and regulated by the Financial Conduct Authority (No. 0310409), registered in England Number 04036555 at New Road, Halifax, West Yorkshire, HX1 2JZ United Kingdom. We are the data controller, which means we are responsible for deciding how your data is used.

Our core policies are underwritten by a single insurer, Royal & Sun Alliance Insurance Ltd (RSA), their privacy notice can be found here. Some additional covers we offer are provided by other insurance providers as detailed below (“Insurance Provider” or “Insurer”).

• Legal expenses: ARC Legal Assistance Ltd  Privacy Notice
• Motorhome breakdown: Inter Partner Assistance Privacy Notice

Throughout this privacy and security notice the term “you” or “your” refers to any customer interacting with us on or off line, and whose data we may hold.

Use of our website

Cookies and other technologies

Cookies, and similar technologies (referred to as cookies going forward), are small text files that allow us to improve your experience on our website, identify your computer, recognise repeat users, personalise content, observe anonymous user behaviour and compile aggregate data about users in order to improve the services we provide.

When you visit our website, your browser will be asked to store cookies, to help remember information about you, such as login information or user preferences. These cookies are set by us, and known as ‘first party cookies’. We also use ‘third party cookies’, which are from a domain other than our website, this is for marketing purposes.

You can manage and / or opt-out of each cookie category (except ‘Essential’ cookies) by following the instructions in the Manage Cookies section.

Further independent information about cookies, the management of cookies, and how to configure your browser to not accept or opt-out can be found here: All About Cookies | Online Privacy and Digital Security

Cookie Categories:
We have categorised below the types of cookies used when visiting our website. A detailed list of cookies used within each category and their lifespan (where applicable), can be found and managed in the Manage Cookies section

Marketing
These are used to serve you ads that are relevant to your interests, when visiting our website and that of third parties. They help us to learn what your interests are when visiting our website and browsing other websites, so that we can provide you with relevant content. If you choose not to accept these cookies, you may not see offers and promotions when visiting our website, or that of third parties, and adverts may be less relevant to your interests.

Functional
These enable us to analyse the use of the website in order to measure and improve its performance. They do not gather information about you that could be used for marketing or remember where you have browsed on the internet, the information collected is usually anonymised. These cookies can also make your quotation and browsing experience easier, remembering fonts, language selection, your username, recently viewed pages on our website etc. Switching off these cookies will mean some areas of our website can’t work properly.

Essential
These are required to activate the core functionality of our website, ensuring services such as gaining an insurance quote, and logging into your account are operational, and work in a secure manner. You cannot turn these cookies off on our website, but you can set your browser to block or alert you about these, some parts of our website however will not then work.

Security

The security of your personal and financial details is of paramount importance to us. That is why our online quote and buy pages use the most powerful SSL encryption commercially available today.

Server-Gated Cryptography (SGC) enables 128 or 256 bit SSL encryption (depending on the browser and host server operating system). This enables us to provide the strongest level on encryption available to you.

It works by automatically scrambling the information you send over the web so it is meaningless. Once it arrives, we have the key to de-scramble the words. When you fill in any personal information or payment details, you will be in a secure area of the site.

You can check this by looking for a padlock in the bottom corner of your web browser and that the web address starts with “https:// ” – the letter ‘s’ stands for secure. When you send your information over the web, it will be encrypted to protect anyone from reading it. All the information that we save for you is protected by firewalls and a wide range of IT security measures.

The information we collect and how we collect it

As a data controller we have certain legal responsibilities concerning how we collect, use and share your personal information. We receive personal information about you from:

• You directly, the information you provide when you contact us.
• Third parties, the information which a third party can lawfully pass to us. This could be where a third party applied for a product on your behalf (and you gave permission for this), an agent lawfully passed your details to us to provide our services, or other sources such as the Motor Insurers Database and fraud prevention databases.

Your information comprises all the details we hold about you and your transactions, including information obtained from third parties. Although not an exhaustive list, the types of personal information we collect include: your name, email address, phone number, postal address, make and model, and other information to assess your insurance risk.

We need to collect data about you so that we can understand the level of insurance cover you require, and to provide you with insurance services and information. We will use some of this information to communicate with you, and where you have agreed, to send you product or service information and offers.

Sometimes we will ask for special categories of personal information (e.g. driving offences, criminal, fraud or health information) for which there is additional protection under data protection law.

Once you become a customer we will collect your payment details, (e.g. direct debit, credit or debit card information) to pay for your cover. To service your policy we might contact you via our website, emails, phone, text or post. These services might record information such as passwords, electronic information identifier (IP Address), email address, phone number and call recordings.

If you need to make a claim against your policy, information about the incident will be collected, this may be shared with other selected companies to aid the processing of the claim.

Legal grounds to process

We are required to tell you the legal grounds relied upon to process your personal information and why processing is necessary, we have listed these below:

• Our performance of an insurance contract
  This includes providing you with insurance (including administration and generally servicing and maintaining your policy) and/or us taking steps at your request towards, and in anticipation of, providing you with insurance services.
• Our Legitimate business interests or those of a third party
  Where these interests are not overridden by your interests or fundamental rights and freedoms in relation to the protection of your personal information. Our legitimate business interests include enabling us to provide you with information about our insurance services, market research, product development, responding to any query that you may raise with us and, where requested by you, providing you with insurance services. Third party legitimate business interests include the provision of data to allow confirmation of cover in place and anonymised market analysis. We will always give full and proper consideration to your interests, via a balancing test, before using your personal information in the way described.
• Consent
  In some circumstances we may need consent to use your ‘special category personal data’.

We will always give you a choice as to whether we use your personal information for marketing, this includes offering a specific choice as to whether The Swift Group can market relevant innovations and offers to you.

• Our compliance with legal or regulatory obligations
• Necessity
  To establish, exercise or defend a legal claim. We may use your information to establish our position or defend ourselves.

For special category personal information (such as criminal convictions), the legal grounds we rely on to process your information are that:

• We need to investigate a potential legal claim or bring or defend a legal claim, this may relate to a claim under your insurance policy, or relate to the investigation and prosecution of fraud. Please note that you do not have to give your consent to us for us to provide our insurance services to you.

How we use your personal information

We think your information is as important as you are, and we want to make you aware of how we might use it:

• To inform you about our insurance services
• To provide you with the service requested
• To undertake administration and generally service and maintain your insurance policy, including responding to any query that may raise, and managing any claims you may make under your insurance policy
• To develop and test products and services, in specific, we may also use your information to contact you for market research purposes
• Recover debt
• Prevent and detect crime

Where you have provided your prior consent:

We will use your contact information to notify you of our services, products and offers which we believe may interest you, via post, phone, email or text, this is what is commonly referred to as ‘marketing’. These messages may be personalised using information you have previously provided.

We may use information collected about you to show you relevant advertising on third party websites e.g. Google, this could be advertising messages via the use of cookies. If you don’t want to be shown targeted advertising from us you can change your settings on some third party sites, and some browsers allow you to block our adverts.

We may ask you to confirm or update your consent choices, if or when you interact with us in the future, to ensure that your choices remain upto date. If at any other time you decide that you do not want us to contact you for marketing purposes, please get in touch using the details in the ‘Contact Us’ section of this privacy notice.

We will not disclose your information to any other party except:

• Where we have your consent
• To service your contract; for example your policy underwriter will require this information to provide you with a quote and / or insurance cover
• To credit reference and fraud prevention agencies and other companies that provide a service to us, our partners or you
• Where a third party has been appointed to handle elements of your claim
• With our carefully selected third party service providers, including external software or hosting providers, research or development agencies and technology providers
• Where you have taken a policy with us, we may send confirmation to the company that introduced you to us (e.g. a dealer, holiday park or member organisations). Personal data will be limited to that used for statistical analysis, confirmation of commission payment, and/or to improve relevancy of their marketing campaigns. Please notify us within 14 days of receiving your policy document if this is not ok.
• Where we are required or permitted to do so by law
• In the event that we are bought or we sell our business, your information will be disclosed to the prospective buyer
• For anonymised market research

Your personal information may be accessed, transferred or stored at a destination outside the European Economic Areas in connection with the purposes set out above. We will take all reasonable steps to ensure that your personal information is safeguarded and treated in accordance with this privacy notice. If you would like further information please contact us.

Automatic Decision Making

Prior to us offering you an insurance product or service we may carry out the below which involve automated decision making (computer based):

• Pricing and Underwriting; to calculate the insurance risk and calculate a premium
• Credit referencing; where a policy is being paid by Direct Debit checks are made to evaluate your credit rating, this is to assess your ability to pay for the product or service

If you do not agree with the result, you have the right to contact us to request a manual reassessment of the same information.

How long will we keep your personal information?

Where you have expressed an interest in our services, or where we have received your contact details for us to provide you with information about our services, we will keep your information for four years after our last mutual contact, or until you ask us to stop sending you such information.

Where you have purchased an insurance product, we will keep your personal information for so long as we are providing you with insurance services, plus an additional seven years, to deal with any queries, complaints or legal claims you may have. We may keep your data for longer than seven years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure your privacy is protected and only use it for those purposes.

Your rights in relation to your personal information

Under certain conditions, you may have the right to request us to:

• Provide you with further details on the use we make of your personal information
• Provide you with a copy of personal information we have collected about you
• Update any inaccuracies in the personal information we hold
• Delete any personal information that we no longer have a lawful ground to use
• Object to our use of your personal information if our use of your personal information is causing you undue harm.

If you have any questions in relation to our use of your personal information, or wish to request any of the above, please get in touch using the details in the ‘Contact us’ section below.

Please note that submitting a request does not necessarily mean we will be able to fulfil it on every occasion, we may be bound by law preventing us from fully fulfilling such a request. When this is the case we will explain in our response.

Contact us

If you have any questions, or if you would like to find out more about this privacy and security notice you can write to us at:

Data Protection Officer
Supersure Insurance at Caravan Guard
New Road
Halifax
HX1 2JZ
Or telephone 01422 396 777

Should it be necessary, you also have the right to complain to the Information Commissioner’s Office, you can find out how to report a concern via their website.