This Privacy Statement (“Statement”) explains Stubben Edge Group’s information processing and use practices. Reference to Stubben Edge Group, Stubben Edge or We shall include all subsidiary companies listed below.

The Statement applies to any personal information you provide to Stubben Edge and any personal information we collect from other sources. This Statement is a statement of our practices and of your rights regarding your personal information. This is not a contractual document, and it does not create any rights or obligations on either party, beyond those which already exist under data protection laws.

This Statement does not apply to your use of a third party site. We may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

Stubben Edge Group Limited a limited company incorporated in England and Wales with registered number 07227141, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ and its subsidiaries are listed in Schedule 1 (“we/Stubben Edge/Stubben Edge Group”). Stubben Edge collects personal information from its clients about their customers to provide financial services, loyalty offerings, IT and Data services. We also collect some personal information directly, for example over our websites, applications, and various group offerings.

Stubben Edge Group is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Stubben Edge uses personal information to deliver services to clients, which includes marketing any financial services offerings and/or what we deem marketing of products that we view to be a legitimate interest. For its own purposes, it also uses personal information to analyse and improve how it delivers those services, to contact representatives of its clients or prospective clients and to market to them.

In the event that we use any of your personal information, you will have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why we use your information.

If you have any questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, or would like to make a complaint about a breach of Data Protection Legislation or this Statement, please contact us on hello@stubbenedge.com. Alternatively, you have the right to contact your local Data Protection Authority.

Do read this Policy with care.  It provides important information about how we use personal data and explains your statutory rights. This Policy is not intended to override the terms of any nor rights you might have available under applicable data protection laws.

Stubben Edge Group Limited is the parent company for Stubben Edge Risk Limited, Lucid Ux Limited, Stubben Edge Wealth Limited, Stubben Edge SA (Pty) Ltd, Stubben Edge Operations Limited, Genesis Special Risks Limited, Akoni Hub Limited, Finpoint Limited,  Cedar Underwriting Limited, Randell Dorling Limited, Stubben Edge Markets Ltd, Stubben Edge Partners Limited and Stubben Edge (Labs) Limited who could be originally responsible for collecting information about you.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;

Contact Data includes billing address, delivery address, email address and telephone numbers;

Financial Data includes bank account and payment card details;

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;

Usage Data includes information about how you use our website, products and services; and

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

In limited circumstances, we may collect Special Categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) when you use some of our specific products and agree to provide us with such information.

If you are a business partner, we will collect your business contact details. We may also collect information about your professional expertise and experience. We may collect your contact details, if you visit our website, register for a newsletter or attend one of our events. If we collect personally identifiable information through our website, we will make it clear when we collect personal information on the basis contained in this notice.

When you interact with Stubben Edge we may collect information on you in the following ways:

We collect information you provide to us when you request or purchase products, services, or information from us, register with us, participate in public forums or other activities on our sites and applications, respond to surveys, visit our physical properties, call our customer support line, or otherwise interact with us using one or more devices. You may provide information in a variety of ways, including by typing or using voice commands.

We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered. Please visit our specific Cookies Notice on the relevant product website for further information.

We collect information using analytics tools, including when you visit our sites and applications or use our applications where they are embedded on third-party sites or platforms.

We acquire information from other trusted third party sources to update or supplement the information you provided, or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to:

Provide you with the experiences, products, and services you request, view, engage with, or purchase on our websites.

Remember you when you visit our websites and to see which product or service information pages and other pages you visit.

Identify your interests. We may use this to create audience segments that we then use to serve targeted, relevant advertising or content to you.

Identify aggregated and anonymised browsing behaviour on the website.

Target advertising to you based on your location.

Provide you with information by email, post or phone, about products or services that you request from us, such as email newsletters, marketing emails and special offers, where you have consented to be contacted for such purposes and by such means.

Ensure the content we display to you on the website is done in the most appropriate and efficient way, such as by identifying the device you are using and formatting the website appropriately.

Perform our obligations under any contracts between you and us and/or in relation to our terms and conditions.

Enable you to participate in any interactive features of our service, when you choose to do so.

Decide how to develop our products.

We may also send you emails to provide information and keep you up to date with developments on our website or regarding the products and services that you use. It is our policy to have instructions on how to unsubscribe so that you will not receive any future e-mails.

If you are a business partner we will use your personal data to manage our relationship with you, including sending you marketing materials (where we have appropriate permissions) and to invite you to events. Where relevant, we will use your personal data to deliver or request the delivery of services, and to manage and administer our contract with you or with your employer. If you are a visitor, we will use your personal data; typically, to register for certain areas of our website, enquire for further information, distribute requested reference materials, or invite you to one of our events.

We routinely analyse information in our various systems and databases to help improve the way we run our business, to provide a better service and to enhance the accuracy of our risk and other actuarial models. We take steps to protect privacy by aggregating and where appropriate anonymising data fields before allowing information to be available for analysis.

We will make sure that we only use your personal data for the purposes set out herein, provided you have provided your consent to us using the data in that way Our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you. Our use of your personal data is necessary to comply with a relevant legal or regulatory obligations which we may have.

Our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to improve our products, or to carry out analytics across our datasets), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.

Before collecting and/or using any Sensitive Personal Data we will establish a lawful exemption which will allow us to use that information.  If your Sensitive Personal Data is collected on a form (including on a website) or over the telephone, further information about the exemption may be provided on that form. This exemption will typically be:

- your explicit consent (if this is specifically requested from you on a data collection form, in language which references your consent);
- the establishment, exercise or defence by us or third parties of legal claims;
- or a specific exemption provided under local laws of EU Member States and other countries implementing the GDPR or exemptions under the UK Data Protection Act 2018.

‍PLEASE NOTE if you provide your explicit consent to permit us to process your Sensitive Personal Data, you may withdraw your consent to such processing at any time. However, you should be aware that if you choose to do so we may be unable to continue to provide services to you.

Who do we share your personal data with?
‍Within the Stubben Edge Group of companies for operational, business purposes and marketing purposes, with your consent.

With third parties where they provide services on our behalf (for example, companies who help us to operate our websites).

When we are legally required to do so (for example, to cooperate with investigations initiated by law enforcement or other legal proceedings).

We may need to share your data with third parties to whom we may choose to sell, transfer or merge parts of our organisation. If this occurs, the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.If you’ve been introduced to us by another company, we may share your information with them to enable them to:

- Administer and service your products.
- Carry out market research, statistical analysis and customer profiling.
- Where you have consented, send you marketing information by post, telephone, e-mail and SMS about their products and those of carefully selected third parties.
- Assist you with your application process (aggregator and price comparison websites only).

We may be under legal or regulatory obligations to share your personal data with courts, regulators, law enforcement or in certain cases other insurers. If we were to sell part of our businesses we would need to transfer your personal data to the purchaser of such businesses who would in turn be in contact with you regarding their Data Privacy processes.

If you have given us your consent or it is in our legitimate interest to do so, we may use your personal data to send you direct marketing communications about our financial service products or our related services. This may be in the form of email, post, SMS, telephone or targeted online advertisements. Our services, which you agree we may market to you in respect of are included but not limited to:  

General Insurance products
Long term insurance products
Financial Service products
Cash management products
Media related services
Events
Information Technology
Software Services

In most cases our processing of your personal data for marketing purposes is based on our legitimate interests to provide information you might find helpful to manage your products, services and offers that may be of interest to you, although in some cases (such as where required by law) it may be based on your consent. You have a right to prevent direct marketing of any form at any time – this can be exercised by following the opt-out links in electronic communications, or by contacting us using the details set out in herein.

We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of legitimate interest or relevance to you, based on the information we have about you.

From time to time we may need to share your personal data with members of the Stubben Edge group who may be based outside Europe (outside of the European Economic Area). We may also allow our Service Providers or Assistance Providers, who may be located outside Europe, access to your personal data. We may also make other disclosures of your personal data overseas, for example if we receive a legal or regulatory request from a foreign law enforcement body.

We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests:

We will only transfer your personal data to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights;

Transfers within the Stubben Edge Group of companies will be covered by an intra-group agreement which gives specific contractual protections designed to ensure that your personal data receives an adequate and consistent level of protection wherever it is transferred within the Stubben Edge Group;

Transfers to Service Providers and other third parties will always be protected by contractual commitments and where appropriate further assurances.

Any requests for information we receive from law enforcement or regulators will be carefully checked before personal data is disclosed.

You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us if you would like further information.

We will retain your personal data for as long as is reasonably necessary for the purposes listed in this Policy. In some circumstances we may retain your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulator, tax or accounting requirements.

In specific circumstances we may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

We maintain a data retention policy which we apply to records in our care. Where your personal data is no longer required, we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.

You have a number of rights in relation to your personal data
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You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, and various information in relation to any Automated Decision Making and profiling or the basis for international transfers. You may also exercise a right to complain to your supervisory authority. More information about each of these rights can be found by clicking on the relevant link or by referring to the table set out further below.
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To exercise your rights, you may contact us as set out HEREIN. Please note the following if you do wish to exercise these rights:

Right
You can ask us to:

confirm whether we are processing your personal data;

give you a copy of that data;

Access
provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any Decision Making or Profiling, to the extent that information has not already been provided to you in this Policy.

Rectification
You can ask us to rectify inaccurate personal data.

We may seek to verify the accuracy of the data before rectifying it.

Erasure
You can ask us to erase your personal data, but only where:

It is no longer needed for the purposes for which it was collected; or
You have withdrawn your consent (where the data processing was based on consent); or

Following a successful right to object; orIt has been processed unlawfully; or
To comply with a legal obligation to which Stubben Edge is subject.

We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:

For compliance with a legal obligation; or

For the establishment, exercise or defence of legal claims;

There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.

Restriction
You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
Its accuracy is contested to allow us to verify its accuracy; or

The processing is unlawful, but you do not want it erased; or
it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or

You have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal data following a request for restriction, where:
we have your consent; or

to establish, exercise or defend legal claims; or

To protect the rights of another natural or legal person.

Portability
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another Controller, but in each case only where:

The processing is based on your consent or on the performance of a contract with you; and

The processing is carried out by automated means.

Objection
You can object to any processing of your personal data which has our ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Automated Decision Making
You can ask not to be subject to a decision which is based solely on automated processing, but only where that decision:

produces legal effects concerning you (such as the rejection of a claim); or
otherwise significantly affects you.

In such situations, you can also obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.

Your right not to be subject to automated decision making does not apply where the decision which is made:

Is necessary for entering into or performing a contract with you;
Is authorised by law and there are suitable safeguards for your rights and freedoms; or

Is based on your explicit consent.

However, in these situations you can still obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.

International Transfers
You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the UK.

We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.

Supervisory Authority
You have a right to lodge a complaint with your local supervisory authority about our processing of your personal data. In the UK, the supervisory authority for data protection is the ICO.

We ask that you please attempt to resolve any issues with us first although you have a right to contact your supervisory authority at any time.

Identity
We take the confidentiality of all records containing personal data seriously and reserve the right to ask you for proof of your identity if you make a request in respect of such records.

Fees
We will not ask for a fee to exercise any of your rights in relation to your personal data, unless your request for access to information is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.

Timescales
We aim to respond to any valid requests within one month unless it is particularly complicated or you have made several requests in which case we aim to respond within three months. We will let you know if we are going to take longer than one month. We might ask you if you can tell us what exactly you want to receive or are concerned about. This will help us to action your request more quickly.

Third Party Rights
We do not have to comply with a request where it would adversely affect the rights and freedoms of other data subjects.

Stubben Edge (Risk) Limited, a limited company incorporated in England and Wales with registered number 09073942, and having its registered offices at Fourth, 75-77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the FCA (FRN:943286). Stubben Edge Risk Limited also trades as Smallbusiness.co.uk, Save More Money and SB Pro.

Genesis Special Risks Limited, a limited company incorporated in England and Wales with registered number 01952005, and having its registered offices at 107 Leadenhall Street London EC3A 4AF, United Kingdom and which is authorised and regulated by the FCA (FRN:311626).

Finpoint Limited, a limited company incorporated in England and Wales with registered number 08846630, and having its registered offices at Pennine Place 2A Charing Cross Road London WC2H 0HF United Kingdom and which is authorised and regulated by the FCA (FRN: 727163).

Akoni Hub Limited, a limited company incorporated in England and Wales with registered number 10462207, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the FCA (FRN: 766340).

Lucid UX Limited a limited company incorporated in England and Wales with registered number 09645039, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ.

Stubben Edge Claims Limited a limited company incorporated in England and Wales with registered number 13562730, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ.

a limited company incorporated in England and Wales with registered number 10435194, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ.

Stubben Edge Events Limited a limited company incorporated in England and Wales with registered number 14292495, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ.

Stubben Edge Media Limited a limited company incorporated in England and Wales with registered number 13367399, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ.

Stubben Edge Payments Limited a limited company incorporated in England and Wales with registered number 13756584, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ.

Duffy Boxing Limited a limited company incorporated in England and Wales with registered number 13946197, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ.

Stubben Edge International Limited company incorporated in the Bailiwick of Guernsey, Company registration number (in Guernsey): 70753 with Registered office at Suite 1 North, 1st Floor, Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ

1Edge Insurance PCC Limited company incorporated in the Bailiwick of Guernsey, Company registration number (in Guernsey): 70415 with Registered office at Suite 1 North, 1st Floor, Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ, and licensed by the Guernsey Financial Services Commission (ref no. 2771296)

Cedar Underwriting Limited a limited company incorporated in England and Wales with registered number 13946197, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the Financial Conduct Authority (FRN: 785986).

Stubben Edge and Partners Limited a limited company incorporated in England and Wales with registered number 07076678, and having its registered offices at 77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the Financial Conduct Authority (FRN: 815500).

Stubben Edge Markets Limited a limited company incorporated in England and Wales with registered number 03317764, and having its registered offices at 77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the Financial Conduct Authority (FRN: 311926).

Randell Dorling Limited a limited company incorporated in England and Wales with registered number 03688419, and having its registered offices at 77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the Financial Conduct Authority (FRN: 311940).

Stubben Edge Payments Limited a limited company incorporated in England and Wales with registered number 13756584, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ.

Duffy Boxing Limited a limited company incorporated in England and Wales with registered number 13946197, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ.

Stubben Edge International Limited company incorporated in the Bailiwick of Guernsey, Company registration number (in Guernsey): 70753 with Registered office at Suite 1 North, 1st Floor, Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ

1Edge Insurance PCC Limited company incorporated in the Bailiwick of Guernsey, Company registration number (in Guernsey): 70415 with Registered office at Suite 1 North, 1st Floor, Albert House, South Esplanade, St Peter Port, Guernsey, GY1 1AJ, and licensed by the Guernsey Financial Services Commission (ref no. 2771296)

Cedar Underwriting Limited a limited company incorporated in England and Wales with registered number 13946197, and having its registered offices at Fourth Floor, 75-77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the Financial Conduct Authority (FRN: 785986).

Stubben Edge and Partners Limited a limited company incorporated in England and Wales with registered number 07076678, and having its registered offices at 77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the Financial Conduct Authority (FRN: 815500).

Stubben Edge Markets Limited a limited company incorporated in England and Wales with registered number 03317764, and having its registered offices at 77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the Financial Conduct Authority (FRN: 311926).

Randell Dorling Limited a limited company incorporated in England and Wales with registered number 03688419, and having its registered offices at 77 Cornhill, London, England, EC3V 3QQ and which is authorised and regulated by the Financial Conduct Authority (FRN: 311940).

The primary point of contact for all issues arising from this Policy, including requests to exercise data subject rights, is our Data Protection Lead

The Data Protection Lead can be contacted in the following ways:

Email: hello@stubbenedge.com

hello@Stubbenedge.com

Write to: Dean Moulder

Data Protection Officer,
Stubben Edge, 77 Cornhill, London, EC3V 3QQ

Write to: Helen Bingham - Data Protection Lead
Stubben Edge, 77 Cornhill, London, EC3V 3QQ
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If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.
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‍Information Commissioner Office – ICO helpline - 0303 123 1113.