Privacy Policy

The pages on this website are only directed at UK residents and comply with appropriate UK legislation and regulation.

This privacy policy has been provided to let you know how we use and look after your personal information which has been shared with our respective Brands. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send to you. The policy also tells you about your privacy rights and how the law protects you when (i) we contact you, (ii) you contact us (iii) you visit our website.

We promise to:

  • Keep your data safe and private
  • Give you ways to manage and review your marketing choices at any time
  • Not sell your data to anyone else

Data Controller

British Seniors Insurance Agency, Smart Insurance, FRANKLi, Zestylife Insurance and Choozi are trading names of Neilson Financial Services Limited. Neilson Financial Services Limited also provide life insurance comparison (aggregator) services on behalf of GoCompare.com Limited, on a “white label” basis (GoCompare Life Insurance).

The data controller is Neilson Financial Services Limited who is authorised and regulated by the Financial Conduct Authority and entered on the Financial Services register www.fca.org.uk/firms/financial-services-register under reference 594926. Neilson Financial Services Limited. Registered in England and Wales. Number 07986483. Registered Office, Landmark Place, Windsor Road, Slough, Berkshire SL1 1JL.

All British Seniors Insurance Agency products sold after 1st May 2018, and FRANKLi products are issued, underwritten and administered by AIG Life Limited (AIG Life) who is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority and entered on the Financial Services Register under reference 473752.

All Smart Insurance and Zestylife Insurance products are issued, underwritten and administered by Scottish Friendly Assurance Society Limited who is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority and entered on the Financial Services Register under reference 110002. 

Where data is provided to our partners in relation to a service you have requested, our partners may also act as data controllers. If you would like more information about how any of our partners process data, you should read the privacy policy for the relevant partner which will be available on the partner’s website. 

Our partner’s and their privacy policy can be found below:

Choozi and GoCompare Life Insurance are insurance intermediaries. Our Choozi and GoCompare Life Insurance partners and their privacy policies can be found below:

 

Data Protection Law

We are conscious of our responsibilities as a "data controller" under the General Data Protection Regulation that came into force on 25th May 2018 and we shall endeavor to ensure that the personal information we obtain and use will always be held, used, transferred and otherwise processed in accordance with that regulation and all other applicable data protection laws and regulations. Neilson Financial Services is registered with the Information Commissioner under registration number ZA125017. If you would like more information about our data protection policy, please contact us using the details shown on our website.

How the Law Protects you

Data Protection Law allows us to use personal information only if we have a clear reason to do so. This includes how we share data outside of Neilson Financial Services. In order to meet this requirement, we will only process personal data in the following circumstances:

  • To fulfil and administer a contract we have with you;
  • When it is in our legitimate interest;
  • When we have a legal duty to;
  • When you consent to it

There are circumstances where an alternative legal basis allows us to process personal data on a legitimate basis. For example, a legitimate interest is when you initiate contact with us to get a quote in order to set up a Policy. Where we rely on an alternative legal basis for processing personal data, we will tell you what it is.

How we use information about you

We may as a result of both your interaction over the telephone, completing and returning application forms and accessing our website via our respective brands, hold and process personal information obtained about you. We have provided examples below of the ways we may use your personal information and why.

When/Where we collect and process your personal information

Legal Basis we can rely on to process personal information

Rationale

When you call us or request to be called back

i) Legitimate Interest

 

ii) Contract

i) Contact initiated by you

 

ii) Applies when you request a quote with a view to entering into a contract with us or to make changes to your existing policy

When we call you to promote and sell our products

Consent

We have evidence of your clear and unambiguous consent to be contacted

When we write to you to tell you about additional products and services.

Consent

You have given your agreement to Marketing

To assess your eligibility for cover

Contract

We need to obtain personal information to determine whether or not we are able to set up a policy for you.

This may involve collecting information from you about your Health and Lifestyle. Without this, we will not be able to proceed with an application for cover.

To contact you for the purposes of notifying you of any important information regarding your Policy.

i) Contract

ii) Legitimate

i) To keep our records accurate and up to date

ii) To update you regarding any changes being made to the Policy

iii) Contacting you to ensure your cover remains in place

To deal with claims, complaints and general enquiries

i) Contract

ii)  Legitimate

i) To Administer claims

ii) Respond to Complaints in line with regulatory requirements and answer any questions you have when you contact us

Transfer data to Third Parties

 

i) Contract

 

i) To enable our underwriters to carry out checks to fulfil regulatory requirements to detect and prevent fraudulent activity

ii) To enable insurers to undertake underwriting activities and to administer your policy

When you agree to take part in a questionnaire or survey

i)Consent

ii) Explicit Consent

i) from time to time, we may ask our customers to participate in a questionnaire or survey. We will only do so for legitimate business purposes, with your consent

ii) The survey may ask you to provide us with sensitive data, such as information about your health. Where this is the case, we will gain your separate, clear and unambiguous consent.

Data Analysis - Profiling: To develop and manage our brands, products and services by understanding our customers behaviours and preferences

 

Legitimate interests

Defining target markets to which products are suited

Using our data to identify new audiences who have a propensity to convert

Charging appropriately for products

Meeting genuine needs of customers through the products we provide

 

Where we collect personal information from:

Data you provide:

  • when you apply for products and services
  • when you talk to us on the phone
  • when you use our websites
  • in letters and emails
  • claims and other supporting documents
  • social media
  • data from third parties we work with
  • companies that introduce you to us
  • comparison websites
  • general practitioners or other medical professionals

When you provide us with personal data about others, you confirm you have their consent to do so including giving us consent to process and use their personal data as detailed in this policy.

Data we collect when you use our services

  • Payment and transaction data
  • Any profile you create or information you provide when you connect to our internet, mobile and telephone services, using cookies

Who we share your personal information with

We may use and share your personal information with service suppliers and financial institutions who we partner with.

If you have purchased a policy via our British Seniors Insurance Agency, Smart Insurance, FRANKLi or Zestylife Insurance brands we will share your personal data with the relevant insurer (either Scottish Friendly Assurance Society Limited or AIG Life Limited), for the purposes of assessing your eligibility to receive such services. This includes the insurer and reinsurer when you apply for insurance through us. Scottish Friendly Assurance Society Limited or AIG Life Limited becomes a data controller when a policy has been issued to you.

If you have purchased a policy via Choozi or GoCompare Life Insurance, we will share your personal data with your chosen providers, for the purposes of assessing your eligibility to receive such services. Your chosen insurance provider becomes a data controller when a policy has been issued to you.

In all instances, our partners will process your personal information for their legitimate business purposes, which includes:

  • making decisions about whether to provide insurance and assistance services (such as claim assessment, claim processing and claim settlement);
  • administering the policy, assessing and paying claims, and general customer service activities (including complaint resolution and claims disputes);
  • detecting, investigating and preventing crime, including fraud and money laundering
  • carrying out market research and analysis;
  • providing information about your policy in connection with any reinsurance; and
  • complying with applicable laws and regulatory obligations (including laws and regulations outside of country of residence).

Whenever our partners use your information for these purposes personal data rights are considered carefully and you have a right to opt-out of this processing. For more information on how to opt-out, please see the relevant partners’ privacy policy.  Links to all privacy policies can be found under the ‘Data Controller’ section above.

 

If we sell our company or part of it, we will share your information with the purchaser, who may then provide you with information on their products and services.

We may transfer and process any personal information you provide to us to countries outside the European Economic Area. Again, we will ensure that all adequate safeguards are in place in connection with such transfer and that all necessary consent has been obtained.

In order to display quotes to you under our Choozi brand or via GoCompare Life Insurance we will send your personal information to our panel of insurance partners.  We need to send them your personal information so that they can generate a quote for us to display on our site.  When these companies use your personal information in this way, they will be acting as data controllers of your personal information which means that they are in charge of how they handle your data and we are not responsible for this.

When you purchase a Product on our Choozi of GoCompare Life Insurance sites, any contract will be entered into between you and the relevant product provider and so we will pass your personal information to them.

If you click through to any of our Choozi or GoCompare Life Insurance partners’ websites, provide them with additional information on their websites and/or if you decide to purchase a product from any of our Choozi or GoCompare Life Insurance partners then they will be data controllers of your personal information and you should read their own privacy policy which you should find under the ‘Data Controller’ section above or on their website.     

 

How we use your information to make automated decisions

To assess your eligibility for cover we may use systems to make automated decisions based on personal information we collect from you. This involves us asking you to answer Health and Lifestyle questions when applying for cover under our Life Insurance Policy. The decision to provide cover is based on the answers you provide. We will hold this data safe and secure at all times. If you are not satisfied with the outcome of the decision returned following completion of the questionnaire, you may ask for this to be reviewed.

If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to administer your policy. It could mean that we cancel a product you have with us.

Any data collection that is optional will be made clear at the point of collection.

Marketing

We can only use your personal information to send you marketing messages to tell you about relevant products and services or offers that may be of interest to you if we have your consent.

Whatever you choose, you will still receive important information relevant to your product, which could include changes to your existing products.

You can ask us to stop sending you marketing messages and update your choices by contacting us at any time.

How long we keep your personal information

We will keep your personal information for as long as you are a customer.

After you stop being a customer, we will keep your data for up to 7 years for the following reasons:

  • to respond to any questions or complaints
  • to show that we treated you fairly
  • to maintain records according to rules that apply to us

We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons. If we do we will make sure that your privacy is protected.

How to get a copy of your personal information

You can access the personal information we hold on you by writing to our Data Protection Compliance Manager. You email us or write to us:

Data Protection Officer at Neilson Financial Services Limited, Landmark Place, Windsor Road, Slough, or email customerservice@neilsonfs.com

Letting us know if your personal information is incorrect

You have the right to question any information we have about you that you think is wrong or incomplete. We will take reasonable steps to check its accuracy and correct it.

If you want us to stop using your personal information

You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using it if there is no need for us to keep it. This is known as the “right to object”, “right to erasure” or the “right to be forgotten”.

However, there may be occasions when we will not be able to delete personal information if a legal or regulatory requirement prevents us from doing so.

Restricting the use of your personal information

You can ask us to restrict the use of your personal information if:

  • it is not accurate
  • it has been used unlawfully, however, you do not want it to be deleted
  • it is not relevant anymore, but you request it is kept for use in legal claims
  • you have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep it on using it.

Opting out of advertising

You can opt out of advertising from Smart Insurance, British Seniors Insurance Agency, Choozi and other brands by making changes on Facebook and Google.

Visit these links to find out how:

Google: https://support.google.com/ads/answer/2662922?hl=en-GB

Facebook: https://www.facebook.com/help/146952742043748

How to withdraw your consent

You can withdraw your consent at any time. Please contact us if you wish to do so.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is the case, we will let you know.

How to Complain

Please contact our Data Protection Officer if you are unhappy with how we have used your personal information. To contact us about any of your rights set out in this Privacy Policy please write to the Data Protection Officer at Neilson Financial Services Limited, Landmark Place, Windsor Road, Slough, or email customerservice@neilsonfs.com. Please provide your full name, email address, date of birth and quote number or policy number when contacting us.

You also have the right to complain to the Information Commissioner’s Office.

enquiries@neilsonfs.com
Neilson Financial Services Limited is authorised and regulated by the Financial Conduct Authority and entered on the Financial Services Register under reference 594926. Registered Office: 2 Windsor Dials, Arthur Road, Windsor, SL4 1RS. Registered in England and Wales, number 07986483. Neilson Insurance Services Canada Inc. is incorporated and registered in Alberta whose registered office is at 850 - 2nd Street SW, 15th Floor, Bankers Court, Calgary, Alberta T2P 0R8. Neilson Financial Services Inc. is incorporated and registered in Ontario whose registered office is at 130 King St W, Toronto, Ontario M5X 2A2.