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1. Who we are

Wills & Co Insurance is a trading style of CRK Motor Insurance Services Limited, a company registered in England and Wales (company number 04924224). We are authorised and regulated by the Financial Conduct Authority (FCA registration number 305804).

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, CRK Motor Insurance Services Limited is the data controller of your personal information.

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Registered address: 20-21 Midland Court, Central Park, Leicester Road, Lutterworth, Leicestershire, LE17 4PN

‍Telephone: 01455 203 505

‍Email: sales@willsandcoinsurance.com

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2. The information we collect

As an insurance intermediary, we need to collect and process personal information to arrange, administer and renew insurance policies on your behalf, and to help you with claims. Depending on the products and services you require, this may include:

• Identity information — name, title, date of birth, and, where required for verification, documents such as your passport or driving licence
• Contact information — postal address, email address, and telephone numbers
• Business information — details about your business, trade, premises, turnover, employees, and business activities relevant to the risks being insured
• Financial information — bank account or payment details, credit history, and premium finance arrangements
• Policy and claims information — details of current and previous insurance policies, claims history, and incident details
• Website and technical information — information collected when you use our website, such as your IP address, browser type, and how you use the site (see section 10 on cookies)

Special category and criminal offence data

In some circumstances, arranging insurance requires us to collect more sensitive information, such as:

• Health information — for example, in connection with employers' liability, personal accident, or claims involving injury
• Criminal conviction information — insurers are legally entitled to ask about unspent convictions, as these can affect the availability and terms of cover

We only collect this information where it is necessary for the insurance products we are arranging, and we process it in accordance with the conditions set out in the Data Protection Act 2018 relating to insurance purposes.

3. How we collect your information

We collect personal information:

• Directly from you, when you request a quotation, complete a proposal form, contact us by phone, email or through our website, or make a claim
• From other people connected to your policy, such as your employees, directors, family members or others named on or covered by a policy — if you provide us with information about other people, you must ensure they are aware of this privacy policy
• From third parties involved in arranging or administering your insurance, including insurers, underwriters, other brokers, loss adjusters, claims handlers, and premium finance providers
• From publicly available sources, such as Companies House and the Financial Services Register
• From fraud prevention agencies, claims databases and credit reference agencies (see section 6)

4. How we use your information and our lawful bases

Under the UK GDPR, we must have a lawful basis for processing your personal information. We use your information as follows:

PurposeLawful basisProviding quotations and arranging, administering and renewing insurance policiesPerformance of a contract (or steps taken at your request before entering a contract)Assisting you with claimsPerformance of a contract; legitimate interestsVerifying your identity and carrying out anti-fraud, anti-money-laundering and sanctions checksLegal obligation; legitimate interestsComplying with our regulatory obligations to the FCA and other authoritiesLegal obligationHandling complaints, including referrals to the Financial Ombudsman ServiceLegal obligation; legitimate interestsManaging our relationship with you, including notifying you of renewals and changes to your policyPerformance of a contract; legitimate interestsRecovering money owed to usLegitimate interestsImproving our services and websiteLegitimate interestsSending you marketing about products and services that may be relevant to youConsent, or legitimate interests where permitted (you can opt out at any time — see section 9)

Where we process special category data (such as health information) or criminal conviction data, we do so under the specific conditions permitted by the Data Protection Act 2018 for insurance purposes, or with your explicit consent where required.

If you do not provide information we reasonably require, we may be unable to provide a quotation, arrange cover, or assist with a claim. Providing incomplete or inaccurate information may also affect the validity of your insurance.

5. Who we share your information with

To arrange and administer your insurance, we may share your information with:

• Insurers, underwriters and Lloyd's syndicates — to obtain quotations and place cover
• Reinsurers — where insurers pass on part of the risk
• Other insurance intermediaries — such as wholesale brokers or managing general agents involved in placing your cover
• Premium finance providers — if you choose to pay by instalments
• Claims-related parties — loss adjusters, claims handlers, solicitors, medical professionals and repairers, where necessary to handle a claim
• Regulators and authorities — including the Financial Conduct Authority, the Information Commissioner's Office, HMRC, the police, and other law enforcement or government bodies where required
• The Financial Ombudsman Service and the Financial Services Compensation Scheme — in connection with complaints or compensation
• Fraud prevention agencies and claims databases — see section 6
• Credit reference agencies — see section 6
• Our professional advisers and service providers — such as accountants, auditors, IT and website providers, who process information on our behalf under contract

We do not sell your personal information to third parties.

6. Fraud prevention, claims databases and credit checks

Insurers and intermediaries participate in industry-wide initiatives to detect and prevent fraud. In connection with your insurance:

• Your details may be checked against and recorded on registers and databases used by the insurance industry, including the Claims and Underwriting Exchange (CUE) and other anti-fraud registers
• Information may be shared with fraud prevention agencies. If fraud is detected, you could be refused certain services, finance or employment
• Insurers or premium finance providers may carry out searches with credit reference agencies to verify your identity and assess creditworthiness, particularly where you pay by instalments. These searches may leave a record on your credit file

7. How long we keep your information

We keep your personal information only for as long as necessary for the purposes for which it was collected, and to comply with our legal and regulatory obligations. In general:

• We retain client records, policy documentation and claims information for a minimum of seven years after the end of our relationship with you or the expiry of the relevant policy
• Records relating to employers' liability insurance may be retained for significantly longer (up to 60 years), reflecting the long-tail nature of injury and disease claims
• Where litigation, a complaint, or a regulatory investigation is ongoing or anticipated, we retain relevant records until the matter is concluded

When information is no longer required, it is securely deleted or destroyed.

8. How we keep your information secure

We take appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, misuse or disclosure. Access to your information is limited to those who need it to carry out their roles, and our staff are trained in their data protection responsibilities.

Your information is primarily stored and processed within the United Kingdom. If any of our service providers or the insurers we work with transfer information outside the UK, we ensure appropriate safeguards are in place, such as UK adequacy regulations or approved standard contractual clauses.

9. Marketing

We may contact you about products and services we believe are relevant to you and your business, including at renewal. You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in any marketing email
• Contacting us on 01455 203 505 or at sales@willsandcoinsurance.com

Opting out of marketing will not affect communications we need to send you about your policy, such as renewal notices and mid-term adjustments.

10. Cookies and our website

Our website uses cookies and similar technologies to make the site work properly and to understand how visitors use it. Cookies are small text files placed on your device.

• Essential cookies — required for the website to function
• Analytics cookies — help us understand how visitors use the site so we can improve it

You can manage or disable cookies through your browser settings, although some parts of the website may not function properly without essential cookies. [Include details of any analytics tools used, e.g. Google Analytics, and any cookie consent tool in place.]

11. Your rights

Under the UK GDPR, you have the following rights in relation to your personal information:

• Access — to request a copy of the information we hold about you
• Rectification — to have inaccurate or incomplete information corrected
• Erasure — to ask us to delete your information in certain circumstances
• Restriction — to ask us to limit how we use your information in certain circumstances
• Data portability — to receive certain information in a structured, machine-readable format
• Objection — to object to processing based on legitimate interests, and to object to direct marketing at any time
• Rights relating to automated decision-making — not to be subject to decisions based solely on automated processing that have a legal or similarly significant effect on you
• Withdrawal of consent — where we rely on your consent, you may withdraw it at any time

To exercise any of these rights, please contact us using the details in section 1. We will respond within one month. There is normally no charge, although we may ask you to verify your identity before responding. Some rights are subject to exemptions — for example, we may need to retain information to meet our legal and regulatory obligations.

12. Complaints

If you have any concerns about how we handle your personal information, please contact us first using the details in section 1 and we will do our best to resolve the matter.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's OfficeWycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AFTelephone: 0303 123 1113Website: www.ico.org.uk

13. Changes to this policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. The latest version will always be available on our website, with the date of the most recent update shown at the top.

14. Contact us

If you have any questions about this privacy policy or how we use your personal information, please contact:

Wills & Co Insurance (CRK Motor Insurance Services Limited)20-21 Midland Court, Central Park, Leicester Road, Lutterworth, Leicestershire, LE17 4PNTelephone: 01455 203 505Email: sales@willsandcoinsurance.com

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