Brockwell Capital understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.brockwellcapital.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
means Optio Group Limited, a limited company registered in England under company number 11032254, whose registered and trading address is 10th floor, 1 Minster Court, Mincing Lane, London, EC3R 7AA, United Kingdom.
2. Information About Us
- Our Site is owned and operated by Optio Group Limited, a limited company registered in England under company number company number 11032254, whose registered and trading address is 10th floor, 1 Minster Court, Mincing Lane, London, EC3R 7AA, United Kingdom. For more information about the Optio Group, please visit their website at https://www.optiogroup.com
- Our VAT number is GB 239437876.
- The person responsible for Data Protection is John Mawson and he can be contacted by email at DPO@optiogroup.com, by telephone number 0203 859 2151 or by post 10th floor, 1 Minster Court, Mincing Lane, London, EC3R 7AA, United Kingdom.
- Optio is the holding company for:
- Ascent Underwriting LLP, a specialist Managing General Agent underwriting on behalf of a number of Lloyd’s Syndicates;
- Cove Programs Insurance Services, a provider of specialty insurance products;
- Bay Risk Services, Ltd a registered Lloyd’s of London Insurance Broker;
- Northcourt Limited, a provider of specialty nuclear products;
- Brockwell Capital Limited, a London based Managing General Agent;
- Optio Underwriting Limited, also trading as Cove Program Underwriting, a Lloyd’s Coverholder; and
- Optio Europe Brokers Ltd, a Maltese regulated insurance intermediary.
3. What Does This Policy Cover?
4. Your Rights
- As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
- The right to withdraw consent – i.e we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
- It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
- business/company name
- job title;
- contact information such as addresses, email and telephone numbers.
6. How Do We Use Your Data?
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account;
- Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link provided in the email.
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email; telephone; text message; post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- Customer details and insurance policies are kept indefinitely in order to support any future claims made.
7. How and Where Do We Store Your Data?
- We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
- Steps We take to secure and protect your data include:
- Regularly changing all passwords to such devices as laptops, computers. Ensure all computers are secure and locked if not in direct use.
8. Do We Share Your Data?
- Subject to section 8.2, We may share some of your data with third parties as outlined below.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal and/or regulatory obligations, a court order, or a governmental authority.
- We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected, by requiring all companies within the group, to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
- Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
- We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
- In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us, which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
- You may access certain areas of Our Site without providing any data at all.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). This is known as a “Subject Access Request”. Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in section 14. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14. To make this as easy as possible for you, a Subject Access Request Form can be made available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- All Cookies used by and on Our Site are used in accordance with current Cookie Law.
- Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
- The following first party Cookies may be placed on your computer or device:
Name of cookie: “_cmsg”
Purpose:This is a first party cookie that’s essential for the operation of the site. You will see a cookie consent feature upon your first visit to our website, whereby one additional cookie will be stored to save the users consent preference and hide the cookie consent message for future visits for a set period of time.
Strictly necessary: YES
- Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
- The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
- The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie:_ga
First/Third Party: Third Party
Purpose: These cookies are used to distinguish users.
- In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
- You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
- It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting Us