Aquarium Software Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we look after your personal data when you visit our website located at https://aqinsure.tech/ (the “Website”) or otherwise interact with us, and it will tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy notice This privacy notice aims to give you information on how Aquarium Software Limited collects and processes personal data that you may give us through your use of the Website, or which you provide to us by phone, SMS, email, in letters and other correspondence or in person. Controller Aquarium Software Limited is the controller and responsible for your personal data (collectively referred to as "Aquarium", "we", "us" or "our" in this privacy notice). Aquarium Casebook and Aquarium Claimsbook are trademarks of Aquarium Software Limited. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this policy. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please email privacy@aquarium-software.com or write to us using the details set out below. Contact details Our full details are: Aquarium Software Limited  FAO: Data Protection Officer Charter House First Floor Woodlands Road, Altrincham. WA14 1HF If you need to know more about your legal rights in relation to personal data please visit the website of the Information Commissioner’s Office (ICO) at https://ico.org.uk/ You have the right to make a complaint at any time to the ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy notice and your duty to inform us of changes We keep our privacy policy under regular review and will place any updates on this webpage. If you disagree with the terms of this privacy policy or any updated privacy policy, you must discontinue use of our services. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. Third-party links on our Website

This Website 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 accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

3. The data we collect 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, last name, username or similar identifier, title and date of birth.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to or from you and other details of products and services you have purchased from us.
• 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.
• Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• 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 or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Personal data collected through the Aquarium platform by our clients Please note that personal data may be collected through the Aquarium platform by our clients who use the Aquarium platform (Client Content).  For example, your personal data may be collected through the Aquarium platform if you are a customer of one of our clients and you have provided personal information to them. This may also include Special Categories of Personal Data.  This privacy policy does not cover the collection or use of Client Content and you should ensure you are familiar with the relevant third party’s own privacy policy if you are providing personal details to them. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, SMS, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our services;
  • request marketing to be sent to you;
  • give us some feedback; or
  • attend an exhibition or event at which you give us your details.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see paragraph 5 below for further details about cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below: • Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU; (b) search information providers based inside or outside the EU.

• Identity and Contact Data from information providers including introducers based inside or outside the EU, in order to provide additional contact and demographic information. • Identity and Contact Data by obtaining a delegate list from exhibition organisers when attending certain events, which may provide personal data about you if you also attend such event(s).

When you access our Website but do not use it to interact with us in any way (for example, by logging into “My Aquarium” or contacting us through the “Contact Us” page) we will collect Technical Data from you, but we do not collect any other type of personal data (including Identity, Contact or Financial Data) unless you provide such data to us, for example by filling in a form or emailing or otherwise corresponding with us. When you interact us with through our Website, for example by logging in to “My Aquarium”, we may collect other categories of data (as set out in paragraph 3 above) from you in addition to Technical Data.

5. How we use your personal data

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

• Where we need to perform the contract we are about to enter into or have entered into with you. • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or SMS. You have the right to withdraw consent to marketing at any time by contacting us either by telephoning +44 (0)161 927 5620 or by emailingprivacy@aquarium-software.com.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us by telephoning +44 (0)161 927 5620 or by emailing privacy@aquarium-software.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.  

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
When you access our Website	(a) Technical (b) Usage	Necessary for our legitimate interests (for running our business, provision of administration and IT services)
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Profile	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to take a survey or complete a questionnaire (c) Responding to your communications (via phone, email, SMS or other)	(a) Identity (b) Contact (c) Profile (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable us to conduct surveys and aggregate user profiles	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Usage	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant Website content to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To allow you to personalise products and services provided through the Website	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To speed up the application process (for example, by collecting personal details we can pre-populate new applications and other forms on the Website saving you time filling in those details)	(a) Identity (b) Contact (c) Profile	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.  You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us either by telephoning +44 (0)161 927 5620 or by emailing privacy@aquarium-software.com at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

To enable us to provide the services available on this Website and to monitor and improve our Website, we may at times gather certain information about you, including Technical Data. We may use cookies only to store information such as your username and your session identifiers to enable us to identify whether you are registered on the Website and, if so, to shortcut your access to the Website. We will only read cookies from your cookie file placed there through your web browser’s interaction with the Website. In most circumstances you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly, such as online forums or previous registration identification. For information on the cookies we use, please click here: https://www.aquarium-software.com/cookie-policy/. For further information on cookies and cookie settings, including how to delete cookies visit allaboutcookies.org

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by telephoning +44 (0)161 927 5620 or by emailing privacy@aquarium-software.com If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

• Credit agencies (such as Creditsafe or Experian) • Banks • Professional advisors, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

It may be necessary for bank or card-processing agencies to verify your personal details for authorisation outside of the European Economic Area (EEA). We sometimes work with certain sub-contractors and service providers and we may provide access to your information to these service providers so that they can assist us in providing our services to you. For example, we use a third party service provider for hosting services, and may use a third party service provider for certain website development services.  We may give relevant persons working for some of these providers access to your information, but only to the extent strictly necessary for them to perform their services for us. 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.

7. International transfers

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to enable us to provide repeat customers with the most efficient service, and for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. Your legal rights

Under certain circumstances, you have certain rights under data protection laws in relation to your personal data: You have the right to: Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us by telephoning +44 (0)161 927 5620 or by emailing privacy@aquarium-software.com If you need to make any changes to your personal data please notify us by speaking to a customer services representative on +44 (0) 161 927 5620. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.   END OF POLICY Version History

Date of change	Summary of change(s)
17/05/2018	Revised Privacy Policy (to include changes for GDPR).