Who are we?
The Just group of companiesƚ are registered under the data protection laws in the United Kingdom and takes 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. From May 2018, it will also include 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
The personal information we hold about you may be shared with the following recipients subject to security, contractual and transfer adequacy safeguards as appropriate:
(a) our group affiliates;
(b) our agents; and
(c) business partners/service providers who assist us in providing the services we offer through our website applications and third party comparison portal(s).
The following categories of agents, business partners and close affiliations assist us in the provision of ancillary services and only use your personal information to the extent necessary to perform their functions:
- Providers for pricing/underwriting purposes: these providers may share your personal information with their group companies for the same purpose.
- Service providers: for the provision of support services such as reinsurance, product administration, receiving and sending marketing communications, data analysis and validation, IT support services, archiving, auditing, business administration and other support services and tasks, from to time.
- Business partners who may have referred you to us: to provide them with relevant management information.
- Other companies in the event we undergo a re-organisation or are sold to a third party.
- Regulators and public authorities who have a legal right to request and process your personal information.
- Other companies in the Just group, where relevant, for management information purposes. ƚ
We may also 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.
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 web 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 and, as of May 2018, the EU General Data Protection Regulation 2016/679 ("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 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, Vale House, Roebuck Close, Bancroft Road, Reigate, Surrey, RH2 7RU
If you remain unhappy with a response you receive from us, you can also refer the matter to the Information Commissioner's Office.
ƚ Just Group of Companies comprising: (Just Retirement Limited, Just Retirement Money Limited, Hub Financial Solutions Limited, Just Retirement Management Services Limited, Just Re 1 Limited, Partnership Home Loans Limited, Paying for Care Limited, Partnership Services Limited, Partnership Life Assurance Company Limited and Partnership Group Holdings Limited.)
The registered office for Just group plc (reg. no. 08568957), Just Retirement group Holdings Limited (reg. no. 06930326), Just Retirement (Holdings) Limited (reg. no. 05078978), Just Retirement Limited (reg. no. 05017193), Just Retirement Money Limited (reg. no. 09415215), HUB Financial Solutions Limited (reg. no. 05125701) and Just Retirement Management Services Limited (reg. no. 04682458) is Vale House, Roebuck Close, Bancroft Road, Reigate, Surrey RH2 7RU. The registered office for Partnership Life Assurance Company Limited (reg. no. 05465261), Partnership Home Loans Limited (reg. no. 05108846) and Partnership Services Limited (reg. no. 05465380) is 5th Floor, 110 Bishopsgate, London, EC2N 4AY. Each company mentioned is registered in England and Wales and a member of the Just group of companies.
Just Retirement Limited and Partnership Life Assurance Company Limited are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. HUB Financial Solutions Limited, Just Retirement Money Limited and Partnership Home Loans Limited are authorised and regulated by the Financial Conduct Authority.