Who are we?
The Just group of companies 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.
What is personal information?
Personal information means any information about you which is personally identifiable, including your name, age, address, telephone number, email address, financial details, and any other information from which you can be identified. This includes genetic and biometric data, location data and online identifiers which may identify you, such as your internet protocol (IP) address (the unique personal address which identifies your device on the internet) and mobile device IDs.
What types of personal information do we collect from you?
We collect the following information about you and your dependants (this includes a person to whom you have granted a power of attorney) when you use our services or we may collect it indirectly from our business partners, such as financial intermediaries:
Personal data: your name, date of birth, telephone number, address, email address, dependants, marital status, IP address and media access control (MAC) address.
Sensitive/special categories of personal data: gender and other sensitive information such as information about your physical and mental health.
Financial information: information that may relate to your financial circumstances (for example your pension values, income and existing investments), bank account details and details of product options you may consider.
Technical and cookies information: information to measure and analyse the use and effectiveness of our services, and to customise the targeting of advertising relating to our services.
How we process your personal information
We will process your personal information for legitimate business purposes or for the performance of a contract in order for us to provide the following:
a) Identify and advise on which products or services best suit your requirements or needs;
b) for administration and to support your choice through updates on policy or product changes;
c) allow you to create an account and communicate with us;
d) to invite you to take part in customer research, potentially using specialist market research;
e) to comply with legal and regulatory obligations;
f) for business and analysis purposes; including protecting your data through secure storage and backups;
g) for the prevention and detection of fraud.
Marketing and Consent
The Just group of companies provide an extensive range of different products and services and may use the personal information you have provided to distribute across the Group (when applicable) to help identify and tailor products and services that may be of interest to you.
We may obtain your, your dependant’s or your appointed Power of Attorney’s consent in order to:
- obtain your marketing preferences and communicate with you in accordance with preferences or options you have selected; through email, telephone or sms;
- to send you marketing literature covering our range of products and services and may continue to do this after your policy has ended; and
- use your personal data for automated decision-making, including profiling for research and marketing purposes as well as actuarial and statistical analysis
We will seek to obtain your explicit consent where we are required to process any special categories of personal data (such as, medical information)
In the event that we intend to process your personal data for new purposes requiring your consent, we will contact you to obtain your consent for such new purposes.
Who we may share your personal information with
We may share your personal information with the following third parties in the circumstances shown.
- Any Just group company, for the uses and purposes set out above
- Intermediaries, advisers and business partners (including our administrator), for the purposes of meeting our obligations to you (for example, providing services)
- Our third-party reinsurers, for the purpose of evaluating and sharing risks
- Third-party service providers, so they can provide essential business services to us or our group of companies (for example, payroll services, data storage and backup, printing, email facilities, auditing and other services)
- Professional and research bodies, when we have to or are asked to do so
- Other third parties, if we have to provide your personal information under any law or regulation that applies, including laws and regulations outside the country you live in
- Other relevant third parties, if necessary as a result of any reorganisation, merger, sale, transfer or other disposal of some or all of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)
Your personal information will only be available to people who need to see it, and it may be made anonymous when it is processed for analysis and research purposes. If possible, we will make your personal information anonymous before we share it with other companies. If the information cannot be made anonymous, we will make sure appropriate confidentiality and security measures are in place.
We will only share sensitive information which is relevant to the service being provided. We will not use it for marketing purposes.
Data retention and anonymisation
Where we have provided you with a service, we will keep your personal information for as long as is necessary for the purposes described in this policy (in line with the data minimisation principle) for a maximum period of 7 years after the service has expired, after which your personal information will be deleted or anonymised in compliance with our established data protection policy.
Anonymised personal information will not be considered as personal since no individual can be identified by that information. We use anonymised information for further actuarial and business analysis, business research and reporting to help us to develop our products and services.
When you visit any Just website or web page, we will only use this information to assist us in providing a more effective service and to collect broad demographic information for aggregate use and to help us to improve our website to deliver a better and more personalised service to:
(a) estimate our audience size and usage pattern;
(b) store information about your preferences, and allow us to customise our website according to your individual interests;
(c) speed up your searches; and
(d) recognise when you return to our Site.
When you visit our website, you can change your cookie preferences through your browser settings.
Monitoring our communications with you
We may monitor or record your calls and text messages and other communications, such as emails, 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 our legal obligations;
(f) in your vital interests;
(g) to prevent or detect crime; and
(h) in relation to our legitimate interests.
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 as required by current data protection laws the UK GDPR.
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.
Transfers of personal data outside of the UK and EEA
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
You have options and choices over how we use your personal information. We may provide you with the tools to manage your account or to change your marketing communication preferences at any time. We may retain a record of your stated objection to the processing of your personal information including in respect of an objection to receiving marketing communications, for the sole legitimate purpose of ensuring that we can continue to respect your wishes and not contact you further, during the term of your objection.
In terms of your rights, you can:
- Request to see the personal information we hold on you.
- Request your data to be corrected or erased where appropriate.
- Restrict/object to the processing of your personal data whilst we investigate your concern.
- In certain circumstances, where your request relates to data you provided to us and where technical possible, you may request to receive your personal data in a commonly used electronic format or send the data in that format to another provider.
- Withdraw your consent to certain processing activities at any time. For example, to object to direct marketing or profiling for market research and marketing purposes.
Requests for your personal information shall be provided free of charge. However, where requests are repetitive, or manifestly unfounded or excessive, we may charge you a reasonable fee to cover the administrative costs of providing the information, or may refuse to act on the request.
- By email at: firstname.lastname@example.org.
- By telephone on: 01737 233288
- By writing to us at: Data Protection Officer, Just Group plc, Enterprise House, Bancroft Road, Reigate, Surrey, RH2 7RP
If you remain unhappy with a response you receive from us, you can also refer the matter to the Information Commissioner's Office.
Just is a trading name of Just Retirement Limited (‘JRL’) and Partnership Life Assurance Company Limited (‘PLACL’) which are subsidiary companies of Just Group plc. JRL is registered in England and Wales, with company number 05017193. PLACL is registered in England and Wales, with company number 05465261. The registered office for both is Enterprise House, Bancroft Road, Reigate, Surrey, RH2 7RP. JRL and PLACL are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Calls may be monitored and recorded, and call charges may apply.