Date: 10 March 2017
Just (comprising Just Retirement Limited, Just Retirement Money Limited and Partnership Life Assurance Company Limited, who are part of the Just group) complies with and are registered under the data protection laws in the United Kingdom and take all reasonable care to prevent any unauthorised access to your personal data.
We respect the privacy of every individual who visits our website (our "Site") and have developed this policy because we want you to feel confident about the privacy and security of your personal information.
We follow strict security procedures in the storage and disclosure of your personal information as required by the Data Protection Act 1998 ("Act").
What is personal information?
Personal data means any information about you which is personally identifiable which include your name, age, address, telephone number, email address, financial details, and any other information from which you can be identified.
What personal information do we collect about you?
We collect the following information about you:
a) your name, date of birth, telephone number, address, email address, gender, dependants, marital status and certain personal sensitive information such as information about your physical and mental health;
b) information that may include (but is not limited to) information relating to your financial circumstances (for example your pension values, income and existing investments);
c) details of annuity options you may consider.
How we process your personal information
We will only use the personal information you provide to us for the following purposes:
1. to provide you with a product quotation;
2. to offer you other suitable products and services by post, telephone or email;
3. to invite you to take part in customer research, potentially using specialist market research ;
4. to comply with legal and regulatory obligations;
5. for general administrative purposes, including the storage and backup of data;
6. for business and analysis purposes;
7. for the prevention and detection of fraud.
Who we will share your personal information with
We may share your personal data with:
a) our reinsurers. In order to get you the most accurate product quotation we need to share information about you, including personal data and personal sensitive data, with our chosen reinsurer. The reinsurers that we share your personal information with, may also use your personal information (either alone or in conjunction with a third party) and may also pass your personal information to their group companies for the following purposes:
- for market research and statistical purposes;
- for gauging sales or product performance; and
- for the prevention and detection of fraud;
Our reinsurers may also pass your personal information to their third party service providers to enable them to underwrite your product quotation. The reinsurers' third parties may reside outside of the European Economic Area ("EEA") and, if necessary, across international borders. The data protection laws in these countries may not be as extensive as in the EEA. These companies are required to process personal information about you in accordance with the Act.
b) other companies in the Just group for the following purposes:
- comply with legal and regulatory obligations;
- for general administrative purposes, including the storage and backup of data;
- for business and analysis purposes;
c) companies outside of the Just group, if you were 'introduced' to us by a third party and/or have a relationship with one of our affinity partners (e.g., an independent financial adviser), we will give them your contact details and sufficient information about you to help with their accounting and administration.
IP Address and Cookies
When you visit our Site we may automatically collect additional information about you such as the type of internet browser or mobile device you use, any Site from which you have come to the Site and your IP address (the unique address which identifies your device on the internet) and your operating system, which are automatically recognised by our web server. You cannot be identified from this information and it is only used to assist us in providing an effective service on the Site and to collect broad demographic information for aggregate use.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They may help us to improve our Site and to deliver a better and more personalised service. They may enable us:
a) to estimate our audience size and usage pattern.
b) to store information about your preferences, and so allow us to customise our Site according to your individual interests.
c) to speed up your searches.
d) to recognise when you return to our Site.
Below we explain the cookies we use and why.
Cookie type: .NET
Cookie name: ASP.NET_SessionId_
Purpose: This cookie is essential for the online experience to remember selections and preferences and is set upon your arrival to the site. This cookie is deleted when you close your browser.
More information: Visit the Microsoft website
Cookie type: Google
Cookie name: __utma __utmz __utmc
Purpose: These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
More information: Visit the Google website
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of our Site.
Monitoring our communications with you
We may monitor or record your calls, emails, text messages and other communications in accordance with UK law, and in particular for business purposes such as:
a) quality control and training
b) processing necessary for the entering into or the performance of a contract
c) to prevent unauthorised use of our telecommunications systems and web sites and/or services
d) to ensure effective systems operation
e) to meet any legal obligation
f) in your vital interests
g) in order to prevent or detect crime
h) the legitimate interests of the data controller
Please visit the Information Commissioner's Office website for further information:
Transmission and security of your personal information
We have security measures in place to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
All information provided to us is stored on secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will try to protect the personal data you provide to us, we cannot guarantee the security of information whilst it is being transmitted to our Site. Any transmission of your information to us across the internet is at your own risk. Once we have received your information, we will use procedures and security features to try and prevent unauthorised access.
In the event that we undergo a re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.
We may disclose your personal information if legally entitled or required to do so (for example if required by law or by a court order or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Site or the right, property or personal safety of any person).
Continued use of the Site will signify that you agree to any such changes.
If at any point we decide to use or disclose information we have collected in a manner different from that stated at the time it was collected, we will notify you.
Your rights to your personal information
If you would like to know what personal information we hold about you, we will provide you with this information on request. You also have the right to correct any errors in that as information.
If any information held is inaccurate, we will make the necessary amendments and confirm to you that these have been made.
If you wish to make a request under the terms of the Act, for the personal information we hold about you, please write to us at the below address:
Data Protection Officer
Just Group plc