Who are we?
Just Retirement Limited, Partnership Life Assurance Company Limited and Just Retirement Money Limited are part of the Just group of companiesƚ and are registered under the data protection laws in the United Kingdom. We take all reasonable care to prevent any unauthorised access to your personal data.
We respect the privacy of every financial intermediary and have developed this policy because we want you to feel confident about the privacy and security of your personal information.
What is personal information?
Personal information means any information about you which is personally identifiable, including your name, address, telephone number and email address.
What types of personal information do we collect from you?
We may collect any of the following information about you when you introduce customers
Personal data: your name, telephone number, address and email address.
How we process your personal information
The personal information we collect may be used in any of the following ways:
Personal data: this information helps us in our legitimate interests (where those interests are not overridden by your interests and rights):
(a) to provide you with information about our services and products;
(b) to perform credit checks and verify your identity;
(c) to comply with legal and regulatory obligations;
(d) for business and analysis purposes, including protecting your data through secure storage and backups and research;
(e) to notify you of important changes or updates to our services;
(f) to maintain a record of your communications with us and for training and service improvement services;
(g) for the prevention and detection of fraud;
(h) to invite you to take part in customer and specialist market research; and
(i) for general administrative purposes.
We comply with the relevant data protection laws when processing customer personal data which you provide to us in accordance with the terms of business.
The Just group of companies provide an extensive range of different products and services. We may be required to obtain your consent in order to:
- send you marketing literature covering our range of products and services; and
- obtain your marketing preferences to communicate through email, telephone or sms.
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:
- Service providers: for the provision of support services such as 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. A list of Just Group of companies can be found in footnote 1. ƚ
In addition, we may 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 the right, property or personal safety of any person.
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.
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), after which your personal information will be deleted from our systems 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.
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 UK current data protection laws.
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 technically possible, request to receive your personal data in a commonly used electronic format or send the data in that format to another provider; and
- 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.
Data Protection Officer
Just Group plc
If you remain unhappy with a response you receive from us, you can also refer the matter to the Information Commissioner’s Office at www.ico.org.uk.
Just is a trading name of Just Retirement Limited. Registered Office: Enterprise House, Bancroft Road, Reigate, Surrey, RH2 7RP. Registered in England and Wales Number 05017193. Just Retirement Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.
Partnership Life Assurance Company Limited. Registered office: Enterprise House, Bancroft Road, Reigate, Surrey, RH2 7RP. Registered in England and Wales under company number 05465261. Partnership Life Assurance Company Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.