Privacy Notice

We respect your privacy and understand that privacy is important to you and that you care about how information about you is used, so this privacy notice sets out details about what data we collect and how we use it.

This policy applies to:

• Your use of the Hapi Protect website
• The provision of insurance broking services by Personal Group Benefits Limited
• The provision of insurance services by Personal Assurance Services Limited
• The provision of insurance by Personal Assurance plc
• The provision of your information to Personal Assurance Services (Guernsey) Limited

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the policy carefully to understand our practices regarding your personal data and how we will treat it.

Data to which this policy applies

This policy applies to the data which is collected on the Hapi Protect website and data we use to provide insurance policies.

The companies which collect data for us are:

Personal Group Benefits Limited – which collects data via the Hapi Protect website and from its sales teams from sales presentations;

Personal Assurance Services Ltd – is passed your data when you take an insurance product with us or as part of the sales process for insurance products;

Personal Assurance plc – is provided with your information where you apply for an insurance product provided by them.

All of the companies have the same registered office which is John Ormond House, 899 Silbury Boulevard, Central Milton Keynes MK9 3XL.

Personal Assurance Services Ltd oversees all of the data management within Personal Group to ensure that we comply with this policy and the data protection rules. Personal Group refers to the companies generally.

Use of data for Hapi Protect

Hapi Protect provides access to insurance products and services provided by us or associated companies. This policy deals with the data we use as a controller. We describe who is using your data below.

Important information and who we are

Our data protection registration number is Z5238745.

We are a group of companies including the following:

• Personal Group Benefits Limited – which collects data via its sales teams from sales presentations;
• Personal Assurance Services Ltd – is passed your data when you take an insurance product with us or as part of the sales process for insurance products;
• Personal Assurance plc – is provided with your information where you apply for an insurance product provided by them.

All of the companies have the same registered office which is John Ormond House, 899 Silbury Boulevard, Central Milton Keynes MK9 3XL.

Personal Assurance Services Ltd oversees all of the data management within Personal Group to ensure that we comply with this policy and the data protection rules. Personal Group refers to the companies generally.

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: Personal Assurance Services Limited
• Email address: info@personal-group.com
• Postal address: John Ormond House, 899 Silbury Boulevard, Central Milton Keynes MK9 3XL

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 14 th May 2025. It may change and if it does, these changes will be posted on this page.

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 our relationship with you.

The data we collect about you

• 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 and title;
• Contact Data includes billing address email address and telephone numbers;
• Financial Data includes details of your payroll account or direct debit account details;
• Health Data includes details of hospital visits and medical conditions. This is information we need to manage your insurance policy;
• Transaction Data includes details about payments to and from you and details of products and services you have purchased from us, including recordings of telephone calls;
• 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 and our services;
• Profile Data includes your username and password, purchases or orders made by you, your interests, 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 your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic 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. 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 may collect Special Categories of Personal Data about you (this includes details about your medical information). We only collect this type of information where you consent to this. We may not be able to provide some services if you do not provide this information (in particular for claims). We do not collect any information about criminal convictions and offences.

How is your personal data collected

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact Data and Medical Data) you consent to giving us about you by filling in forms on Hapi, at meetings with our sales team, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use Hapi or any of our services and when you report a problem with Hapi or our services. If you contact us, we will keep a record of that correspondence;
• Information we collect about you and your device. Each time you use the Hapi Protect website or portal we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our Cookie Policy for further details.

Cookies

We use cookies to distinguish you from other users of Hapi Protect and to remember your preferences. This helps us to provide you with a good experience when you use Hapi Protect and also allows us to improve the Hapi Protect website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy .

How we use your personal data

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

• Where you have consented before the processing;
• Where we need to perform a contract, we are about to enter or have entered 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.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

Disclosures of your personal data

We only share your personal data with the companies set out above, Personal Assurance Services (Guernsey) Limited and our data processors.

Personal Assurance Services (Guernsey) Limited provides Death Benefit insurance policies. It provides cover in the UK but does not operate in the UK. We provide information including personal data for policyholders to it on behalf of policyholders. Personal Assurance Services (Guernsey) Limited is the data controller for that information and uses your personal data for the purposes of providing its insurance policies.

Our data processors provide services to us which involve processing personal data and are all subject to contracts which require their compliance with the Data Protection legislation. Our data processors include third parties who host our websites and platforms along with professional support services such as our audit providers.

International transfers

We do not generally transfer your personal data outside the UK or the EEA. In the limited circumstances where your data may be accessed or transferred outside the UK or EEA this is subject to the UK data protection requirements and will still be protected.

Data security

All information you provide to us is stored on secure servers located in the EEA. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Hapi Protect, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you are no longer entitled to use Hapi Protect we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following 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: 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: You can object where we are relying on a legitimate interest (or those of a third party) and you feel it impacts 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 your personal data in a structured, commonly used, machine-readable format. 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. 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 services to you.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at info@personal-group.com OR 0800 542 5930

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third party processors

We will use some external third parties to process data for us. Where we do this contracts are in place to ensure that the third parties act appropriately with your data. There are third parties who act for us and not those who process your data as outlined in the “Use of Hapi data” section. The processors are:

Service providers acting as processors based in the UK and EEA who provide IT and system administration services.

Professional advisers based in the UK.