Privacy & Cookie Policy

Before you supply any personal details to us via the contact form on this website please read our customer privacy notice in full. This notice sets out how we will process your personal data in line with the General Data Protection Regulations.

Once you have read the customer privacy notice, please tick to confirm that you have read it and that you agree to Libra Financial Management (UK) Ltd processing your personal information for the purpose of contacting you. We will not use the details you provide us in the contact page to market to you unless you expressly opt-in to receive occasional marketing communication from us, which can be opted-out of at any time.

Why Should You Read This Document?

During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What Do We Mean by “Your Personal Data”?

• Your Personal Data means any information that describes or relates to your personal circumstances.
• Your Personal Data may identify you directly, for example your name, address, date of birth, national insurance number.
• Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

In the context of providing you with assistance in relation to your Insurance requirements Your Personal Data may include:

• Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
• Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
• Any pre-existing insurance products and the terms and conditions relating to these The basis upon which our firm will deal with Your Personal Data

When we speak with you about your insurance requirements we do so on the basis that both parties are entering a contract for the supply of services. In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject. The basis upon which we will process certain parts of Your Personal Data

Where you ask us to assist you with for example your insurance, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance providers in relation to insurance products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you.

If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.

The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.

We will use Special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice. Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.

How Do We Collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to insurance. You will provide information to us verbally and in writing, including email.

We may also obtain some information from third parties, for example, credit checks, information from your employer and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data, for example software that is able to verify your credit status, we will only do so if we have consent from you, for us, or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

Cookies and tracking: We use cookies and similar tracking technologies on our website to analyze trends, administer the website, track users’ movements around the website, and gather demographic information about our user base as a whole.

Users can control the use of cookies at the individual browser level. For more information about our use of cookies and other tracking technologies, as well as how to opt out of the use of cookies, please refer to our How LibraInsure.com Uses Cookies section below.

How LibraInsure.com Uses Cookies

Cookies are used in order to make our website work and to make it work more efficiently.

Cookies are broken down into the following categories:

• Strictly Necessary
• Performance
• Functionality
• Marketing

Strictly Necessary

PHPSESSID
Used for managing your sessions on our website. It is persistent and expires once you close the browser tab or window that the website is in.

wordpress_test_cookie
Used to check if cookies are enabled on your browser. It is persistent and expires once you close the browser tab or window that the website is in.

Functionality

hasConsent
Used for when you click to close the privacy notification when first visiting the website. It will keep that closed state for a year or when you clear your browser history.

Performance

Google Analytics
These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the website from and the pages they visited.

Marketing

Facebook/Meta Pixel
These cookies are set by Facebook/Meta as part of their embedded services on our website (clicks, likes, sharing etc.).

How To Change Your Cookie Settings

Most web browsers allow some control of most cookies through the browser settings. Please visit the browser developer’s website to find out how to change these settings.

To opt out of being tracked by Google Analytics across all websites, visit Google Analytics Opt-out Browser Add-on.

What Happens to Your Personal Data When It Is Disclosed to Us?

In the course of handling Your Personal Data, we will:

• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
• Submit Your Personal Data to Insurance Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.

Sharing Your Personal Data

From time to time Your Personal Data will be shared with:

• Insurance providers
• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our compliance advisers, product specialists (in each case where we believe this to be required due to your particular circumstances).
  In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your insurance enquiry and to provide you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages, it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

If data is transferred outside the EEA whether the transfer is made on the basis of an adequacy decision by the European Commission under Article 45 of the UK GDPR. If the transfer is not made on the basis of an adequacy decision, give people brief information on the safeguards put in place in accordance with Article 46, 47 or 49 of the UK GDPR.

Security and Retention of Your Personal Data

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper form for a minimum period of 6 years following the advice/service you receive from us, although your data could be held for a longer period where this may be needed to meet the requirements of our regulatory bodies.

Your rights in relation to Your Personal Data

You can:

• request copies of Your Personal Data that is under our control
• ask us to further explain how we use Your Personal Data
• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
• ask us to send an electronic copy of Your Personal Data to another organisation should you wish
• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to Make Contact With Our Firm in Relation to the Use of Your Personal Data

If you have any questions or comments about our privacy policy, compliance, or wish to make contact in order to exercise any of your rights set out within it please contact:
Austin Mason – austin@librainsure.com

If you wish to register a complaint, please write to or telephone Austin Mason, +44 (0) 208 903 6655 or austin@librainsure.com

A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request and if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service at www.financial-ombudsman.org.uk or by contacting them on 0800 023 4567.

The Guidance And/or Advice Contained Within This Website Is Subject to the UK Regulatory Regime

If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.