Stable Group Ltd (“Stable”, “We”, “Us”, “Our”) is committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal information that you provide to us or which we collect about you will be processed by us. Please read the following carefully to understand how we will use your personal information and your rights in relation to your personal information.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE TYPES OF DATA WE COLLECT
- HOW IS YOUR PERSONAL DATA COLLECTED
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS OF DATA
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. Important information and who we are
Stable Group Limited (company number 10289382) is a company registered in England and Wales with its registered office at 3 Whitehall Court, Whitehall, London SW1A 2EL, UK.
References to “Stable”, “we”, “us” or “our” in this privacy notice, refer to Stable Group Limited.
Controller
Stable is the data controller and is responsible for your personal information.
We have appointed a data privacy manager who is responsible for overseeing privacy matters. If you have any questions about this privacy notice, including any requests to exercise
your legal rights please contact the data privacy manager by emailing
privacy@stableprice.com
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
Third party sites
Our site may, from time to time, contain links to and from the websites of other businesses. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for their privacy obligations. Please check their privacy notices before you submit any personal data to these websites.
2. The types of data we collect
Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The type of personal data we collect about you depends on who you are and your relationship with Stable. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
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- Identity Data includes first name, last name, date of birth, membership number, username or similar identifier, details of your farming business, employer and position/title.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes your bank details so that claims payments can be made to you. We do not collect your card details as these are handled for us by our payment processors.
- Verification Data includes the checks we undertake
to make sure that you are who you say you are and that you have a genuine insurable interest to insure with us. We use your Identity Data and Contact Data to carry out these checks with third parties. - Transaction Data includes details of payments by you and payments to you and details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does
not directly or indirectly reveal your identity. For example, we may aggregate statistics to understand usage of our site.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How is your personal data collected?
If you are a farmer or other individual customer of our insurance
products
If you are a farmer or other individual customer of our insurance products, we will use the following methods to collect data from and about you:
- Direct interactions. You may give us your Identity Data, Contact Data, Financial Data, Transaction Data and Marketing and Communications Data by completing a quotation request and filling in forms on our website, by taking out a policy of insurance with us and by corresponding with us. This includes personal information you provide when:
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- You complete a quotation request;
- You purchase or enter into negotiations to purchase a contract of insurance from us;
- You chat with us via our website help chat;
- You email us to find out about our products and services;
- You register to receive our newsletters and other marketing information; or
- You provide us with feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Notice for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
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- Identity Data and Contact Data from the industry body, co-operative or mutual through whom you are purchasing our insurance products.
- Verification Data from credit reference agencies and other insurance companies including Experian Limited whom we use to check your identity and verify that you are who you say you are.
- Verification Data from the Rural Payments Authority, whose data we use to check that you are a genuine farm.
- Identity Data and Transaction Data from the companies we use to collect the payment of your premium.
- Technical Data and Usage Data from analytics providers such as Google Analytics when you visit our website and purchase our products.
If you are a corporate customer of our insurance products
If you are a corporate customer of our insurance products, we will use the following methods to collect data from and about you:
- Direct interactions. You may give us your Identity Data, Contact Data, Transaction Data and Marketing and Communications Data by completing a quotation request and filling in forms on our website, by taking out a policy of insurance with us and by corresponding with us. This includes personal information you provide when:
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- You complete a quotation request;
- You purchase or enter into negotiations to purchase a contract of insurance from us;
- You chat with us via our website help chat;
- You email us to find out about our products and services;
- You give us your business card so that we may contact you;
- You register to attend events we organise or to receive information we make available; or
- You provide us with feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Notice for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
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- Identity Data and Contact Data from your employer.
- Technical Data and Usage Data from analytics providers such as Google Analytics when you visit our website and purchase our products.
- Identity Data and Contact Data from publicly available sources such as LinkedIn, Facebook, Twitter and other websites and industry bodies and event organizers.
If you are a sales or insurance partner or a business contact,
prospect or website visitor
If you are or work for one of our sales partners or insurance partners or are a business contact, prospect or website visitor, we will use the following methods to collect data from and about you:
- Direct interactions. You may give us your Identity Data, Contact Data and Marketing and Communications Data by corresponding with us. This includes personal information you provide when:
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- You give us your business card so that we may contact you;
- You email us to find out about our products and services;
- You contact us through our website;
- You become or enter into negotiations to become a sales or insurance partner;
- You communicate with us via our platform; or
- You register to attend events we organise or to receive information we make available.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Notice for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
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- Identity Data and Contact Data from your employer if you work for one of our sales partners or insurance partners.
- Technical Data and Usage Data from analytics providers such as Google Analytics when you visit our website.
- Identity Data and Contact Data from publicly available sources such as LinkedIn, Facebook, Twitter, other websites and industry bodies and event organizers.
4. How we use your personal information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
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- Where you have given your consent to the processing of your personal data for a particular purpose.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where it is necessary for the performance of a contract with you.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal information
We have set out below a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data.
If you are a customer of our products and services: |
|
|---|---|
| Purpose/Activity | Lawful basis for processing including basis of legitimate interest |
| To provide you with a quotation and/or contract of insurance that you have requested | Performance of a contract with you |
| To create a user account and administer the products you have requested including administration and assessment of claims and to manage and collect payments. |
|
| To carry out identity and verification checks |
|
| To provide our sales partners with details of commission due to them. | Necessary for our legitimate interests (sales partners market and sell our products to you and they are remunerated by commission payments) |
| To provide our insurance partners with details of the insurance products that you have purchased, premiums due to them and claims payable by them. | Necessary for our legitimate interests (our insurance partners provide the insurance cover you request through us) |
To manage our relationship with you which will include:
|
|
| To invite you to our events and send you our newsletters and other marketing information |
|
| To administer and protect our business and site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
| To use data analytics to improve our site, products/services, marketing, customer relationships and experiences | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
If you are a sales or insurance partner or a business contact, prospect or website visitor: |
|
| Purpose/Activity | Lawful basis for processing including basis of legitimate interest |
| To register you as a sales or insurance partner user and set up your user account so that you can access information from our site | Under contract with a sales or insurance partner, at the request of a sales or insurance partner |
| To build a database of contacts and prospects who might be interested in promoting or purchasing our products and services and to inform our marketing and sales activities, including market mapping, client and prospect mapping and analysis | Necessary for our legitimate interests (so that we can market and sell our products and services) |
| To invite you to our events and send you our marketing communications |
|
| To administer and protect our business and site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
| To use data analytics to improve our site, products/services, marketing, customer relationships and experiences | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Verification of who you are
Because we are supplying you with an insurance product, we have to check that you are who you say you are and that you have an insurable interest to insure.
To verify your identity, we supply your name, address and date of birth to Experian Limited. Experian will check these details against various databases (public or otherwise) to which they have access. They may also use your details in the future to assist other companies for verification purposes and they will retain a record of the search.
To verify that you have an insurable interest, we may check that you represent a genuine farm by matching your address details with publicly available information from the Rural Payments Authority.
Marketing
If you are an individual customer of our insurance products, you will only receive our marketing communications if you have consented to receive them and you have not unsubscribed from our marketing communications.
If you are employed or engaged by a company you may receive our marketing communications if you have requested information from us, if you provided us with your details or if we have identified you as someone who may be interested in our products and services and you have not unsubscribed from our marketing communications.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing
privacy@stableprice.com at any time.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our
Cookie Notice.
5. Disclosures of your personal data
In order to provide our products and services and to run our business, we share your personal data with the parties set out below.
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- Our insurance partners being RFIB Group Limited, a Lloyd’s broker which is regulated by the Financial Conduct Authority to offer insurance products and which places our insurance products with our lead insurer, Ascot Underwriting Limited, and other insurers and reinsurers.
- Bluefriars Brokers Limited which is regulated by the Financial Conduct Authority and which provides us with regulatory compliance services.
- Our sales partners who have introduced you to the Stable insurance products.
- Service providers acting as processors who we use to help manage our business, for example, cloud hosting providers and messaging service providers. Please email privacy@stableprice.com for details of our current service providers, some of which are based in the US.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Regulators, law enforcement agencies and other authorities if required by such authorities or by Due process of law.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers of data
Some of your personal data may be transferred, stored and/or processed outside of the UK and the European Economic Area (EEA) as our suppliers sometimes operate from outside of these jurisdictions. We will only transfer your data outside of the UK and the EEA in compliance with data protection laws and provided appropriate or suitable safeguards are in place to protect your data, these being either Standard Contractual Clauses, Binding Corporate Rules or, in the case of transfers to the US, a Privacy Shield certification. Please email
privacy@stableprice.com if you would like details of the appropriate safeguards.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, destroyed or damaged or used or accessed in an unauthorised or unlawful way.
We limit access to your personal data to those employees, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a data breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will retain your personal data for as long as necessary to provide you with our products and services. We will also retain your personal data as necessary to fulfil our contractual obligations and to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will retain personal data that is part of our marketing database for a period for which we think that information is relevant. We actively manage our marketing database so that only relevant personal data is retained.
Where we no longer need to process your personal data for the purposes set out in paragraph 4 of this Privacy Notice, we will delete your personal data from our systems unless we need to retain a limited amount of information to make sure that we act in accordance with your wishes.
Where permissible, we will also delete your personal data on your request. Information on how to make a deletion request can be found in
Your legal rights.
If you have questions about our data retention practices, please contact us by emailing
privacy@stableprice.com
9. Your legal rights
You have certain legal rights with respect to your personal information which you can exercise at any time by contacting us at
privacy@stableprice.com
| Your Rights | What does this mean? |
|---|---|
| Right of access | You have the right to access any personal data we hold about you: we will provide a copy of your personal data that we hold together with details of the purposes of the processing, the types of personal data we hold and the people to whom your personal data has been disclosed. |
| Right to rectification | You have the right to have inaccurate or incomplete personal data corrected or to restrict the processing of personal data whilst the accuracy is checked. |
| Right to erasure | You have the right to ask to have personal data we hold about you erased. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. |
| Right to data portability | In certain circumstances, you have the right to have data we hold about you transferred to yourself or another data controller. Note, this right only applies to information that is processed by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you. |
| Right to object | You have the right to:
|
| Right to withdraw consent | You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. |
| Right to complain | You have the right to lodge a complaint with the UK Information Commissioner’s Office https://ico.org.uk/concerns/ or other data protection supervisory authority applicable to you if you are unhappy with the way we are handling your personal data. |
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
