PRIVACY POLICY

This Privacy Statement will help you understand how we collect, use and protect your personal information when you interact with us. Please take a few moments to read the sections below and learn how we may use your personal information. You should also show this notice to anyone else who may be insured to drive under your policy. You acknowledge that by providing your personal information to us, you consent in its processing in accordance with this Privacy Statement. We are unable to offer you any insurance product unless you provide explicit consent for the collection and use of such sensitive data as defined in the Data Protection Act 1998.

Gladiator is a trading name of Able Insurance Services Ltd (Able). Able is part of the Admiral Group plc (Gladiator, Ellipse, Ground Floor, Padley Road, Swansea, SA1 8AN, FSA Registration 311649)

Personal
We will collect your personal information when:

• You ask for a quote
• You purchase our products and services
• You make customer enquiries
• You register for information or other services
• You register a claim
• You respond to communications or surveys
• When providing information about others who may be insured you confirm that you have the consent of these individuals to supply their personal information.

The type of personal information we may collect could include:

• Name and address, date of birth and gender
• Telephone numbers and email address
• Credit/ debit card details
• Lifestyle and other information
• We may also collect information defined as "sensitive data" within the Data Protection Act 1998. This includes:
• Medical history
• Claims history
• Criminal convictions etc.

We may also monitor or record calls, emails, text messages or other communications in accordance with UK law, and in particular for:

• Business purposes such as quality control and training
• Processing necessary for entering into or performance of a contract
• Prevention of unauthorised use of our telecommunication systems and websites
• Ensuring effective systems operation
• Meeting any legal obligation
• Protecting your vital interests
• Prevention or detection of crime
• For the legitimate interests of the data controller.

Please visit www.ico.gov.uk for further information.
All personal information will be held in the strictest confidence and used only for the purposes for which we collect it. If you would like us to remove any personal information from our records, then please write to us at Gladiator, Customer Services Department, Ellipse, Ground Floor, Padley Road, Swansea, SA1 8AN. We will make all reasonable efforts to delete your information from our files if it is deemed appropriate.

Non-personal information collected online

Cookies

We use cookies for a number of reasons, including:

• Enabling users to obtain quotes from our website (session cookie);
• Ensuring the security of our customers (session cookie);
• Making possible certain site functionality (session cookie); and
• Website traffic and visitor behaviour tracking (persistent cookie).

The session cookies that we use are strictly necessary for the website to operate and are essential to make possible certain site functionality, including obtaining a quote and also to protect the security of our customers.

The persistent cookies used on this website help us to improve the user experience and structure of our website by collecting anonymous data about how it is being used. These are Google Analytics cookies. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

For information about how to manage and disable cookies you can use the ‘Help’ function within your browser or please visit www.aboutcookies.org or www.allaboutcookies.org.

Please be aware that our website contains links to and from other websites. We accept no responsibility or liability for the content of these websites or the cookies they use. If you choose to visit another website via our website, you will need to contact them separately to have your personal information deleted from any records they might hold.

If you would like more information regarding cookies or our use of them, please read our online Cookie Policy or contact the Data Protection Officer at the following address: Data Protection Officer, Able Insurance, Capital Tower, Greyfriars Road, Cardiff, CF10 3AZ

General
We will use your information for:

• Processing your quotes
• Administering your policy including claims handling
• Fraud prevention and detection
• Administering debt recoveries
• Verifying your identity when required
• Undertaking market research and statistical purposes
• Keeping you informed about promotions and new developments by email, telephone, SMS or post.

Dealing with Other People

Policy Administration
It is our policy to deal with your spouse, partner or parent and any other person who is named on your policy.   If you would like someone else to deal with your policy on your behalf on a regular basis please let us know.

Marketing
Able will also use your information for marketing purposes:

• Contacting you by telephone after your quote; in many circumstances by speaking to you directly, we may be able to offer you a more competitive price

• Keeping you informed of products and services, including but not limited to car insurance (e.g. other automotive or financial products, or other carefully selected offers which we believe may interest you), from us and other companies.

If you do not want your personal information to be used this way, please write to the Marketing Department, Gladiator, Ellipse, Ground Floor, Padley Road, Swansea, SA1 8AN, who will ensure that your information is not used for these purposes.

At renewal
In order to offer you continuous cover on your policy, Gladiator will arrange for your policy to be automatically renewed. You should be aware that we can only guarantee automatic renewal when:

• You have made us aware of any changes to your policy details
• The credit/ debit card details have not changed
• The credit/ debit card holder has given their explicit consent to his or her card being charged at renewal.

Unless we hear to the contrary, Gladiator is entitled to assume at renewal that your details have not changed and you have the consent of the card holder.

If you wish to make changes to your policy then, unless you inform us otherwise, Gladiator will charge the payment details (card or bank account) held on record for any additional amount due.
You may inform us of any changes or opt out of automatic renewal at any time by contacting our Customer Service department.

We will also contact you with a reminder that your insurance is due for renewal.

We will endeavour to treat your personal information as private and confidential.

We would like to bring to your attention our obligations to disclose information in the following four exceptional cases permitted by law, and the other situations set out below. These are:

• Where we are legally compelled to do so
• Where there is a duty to the public to disclose
• Where disclosure is required to protect our interest
• Where disclosure is made at your request or with your consent.

Also, from time to time we will employ agents and subcontractors to process your personal information on our behalf. The same duty of confidentiality and security will apply to them and all processing will be carried out under our instruction.

If you make a complaint about the service we have provided, we may be obliged to forward details about your complaint, including your personal information, to the relevant ombudsman. You can be assured that they are similarly obliged to adhere to the Data Protection Act and keep your personal information strictly confidential.

In the unfortunate event that you have to make a claim then we will need to disclose information with any other party involved in that claim. This may include:

• Third parties involved with the claim, their insurer, solicitor or representative
• Medical teams, the police or other investigators.

If necessary we may also have to investigate your claims and conviction history in the course of administering the claim. You can be assured that we will keep such investigations strictly confidential.

Insurers pass information to the Claims Underwriting and Exchange Register, run by Insurance Database Services (IDS) and the Motor Insurance Anti-Fraud and Theft Register, run by the Association of British Insurers (ABI). This helps insurers check information and prevent fraudulent claims. When we deal with your request for insurance we may search these registers. Under the conditions of your policy, you must tell us about any incident (such as an accident or theft) which may give rise to a claim. When you tell us about an incident we will pass information to the Registers.

Your policy details will be added to the Motor Insurance Database (MID), run by the Motor Insurers' Information Centre (MIIC). MID data may be used by the DVLA and the DVLNI for Electronic Vehicle Licensing and by the police for establishing whether a driver's use of a vehicle is likely to be covered by a motor insurance policy and/or for preventing and detecting crime. If you are involved in an accident (in the UK or abroad), other UK insurers, the Motor Insurers' Bureau and MIIC may search the MID to obtain policy information. Persons pursuing a claim in respect of a road traffic accident (including citizens of other countries) may also obtain information which is held on the MID. Find out more at www.miic.org.uk.

We make searches about you at credit reference agencies who will supply us with information, including the Electoral Register and credit information. The agencies will record details of the search whether or not your application proceeds. The searches will not be seen or used by lenders to assess your ability to obtain credit. We may use scoring methods to assess this application and to verify your identity. Credit searches and other information which is provided to us and/ or the credit reference agencies, about you and those with whom you are linked financially, may be used by Able Insurance and other companies if you, or other members of your household, apply for other facilities including insurance applications and claims. This information may also be used for debt tracing and the prevention of money laundering as well as the management of your account. Alternatively, we may ask you to provide physical forms of identification.

Fraud prevention and detection notice
In order to prevent and detect fraud insurers may, at any time:

• share information about you with our other group companies

If false or inaccurate information is provided and fraud is identified details will be passed to fraud prevention agencies.

Law enforcement agencies may access and use this information.

We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

• checking details on applications for credit and credit related or other facilities
• managing credit and credit related accounts or facilities
• recovering debt
• checking details on proposals and claims for all types of insurance
• checking details of job applicants and employees

Please contact us on 0800 052 3144 if you want to receive details of the relevant fraud prevention agencies.

We and other organisations may access and use, from other countries, the information recorded by fraud prevention agencies.

We may also disclose information about you and your policy:

• To companies within the Admiral Group (For the purposes of this Privacy Statement, "Admiral Group" means Admiral Group plc and any company or entity in which Admiral Group plc owns more than 15% of the issued share capital. Companies in the Admiral Group shall include, without limitation, EUI Limited, Admiral Insurance Company Ltd, Admiral Insurance (Gibraltar) Ltd, Inspop.com Ltd, Able Insurance Services Ltd and any other company that is incorporated within the Admiral Group at any time in the future)
• In the event that we undergo re-organisation or are sold to a third party, in which case you agree that any personal information we hold about you may be transferred to that re-organised entity or third party
• Where it is necessary to deliver the products and services bought by you. For example, we may disclose your personal information to a credit card company to validate your credit card details and obtain payment. It may also be necessary for us to pass your personal information to the organisation from whom you have ordered any products or services other than your Able insurance product, such as a travel insurance or a personal accident cover provider, etc. At all times, Able will remain the Data Controller unless we inform you otherwise

On our websites we protect any information you have given us by providing you with a User ID and password. We also use industry standard secure sockets layer (SSL) 128 bit encryption technology to encrypt sensitive information in transit to our servers.

The User ID and password helps us to protect your personal information. You may need a User ID and password to access your personal information on our website. You must keep this password safe and must not disclose it to anyone. We will accept no responsibility or liability if a third party obtains and uses your User ID and password. You must tell us immediately if you have lost your User ID or password, or if you believe a third party may have obtained it. Please also tell us if you would like us to change your User ID or password for any reason.

When you ask for a quote from us, we will process the data on a secure server. Microsoft Internet Explorer and Netscape Navigator will confirm that you are in a secure area by displaying an unbroken key or lock in the bottom right hand corner of your browser window.

Some organisations have a security feature called a firewall to protect their computer systems. These firewalls may prevent you from connecting to our secure server to get a quote. If you are at work and cannot connect to our site, please speak to your IT administrator to learn more.

Please be aware that communications over the Internet, such as emails or webmails, are not secure unless they have been encrypted.

Your communications may route through a number of countries before being delivered – this is the nature of the Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

It may be necessary to transfer your personal information to other Group companies or service providers located outside of the European Economic Area. The data protection and other laws of these countries may not be as comprehensive as those in the UK or the EEA – in these instances we will take steps to ensure that your privacy rights are respected.

You can write to us at any time to obtain details of the personal information that we may hold about you. Please write to the Data Protection Officer, Able Insurance, Capital Tower, Greyfriars Road, Cardiff CF10 3AZ. Please provide your name, address and policy number and tell us what information you would like.

We will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you. Please provide two forms of identification such as a copy of a driving licence, passport, or document containing your signature, and a copy of a recent utility bill that confirms your address.

In accordance with the Data Protection Act 1998, we are entitled to charge £10 to cover the administration costs. Please make cheques payable to "Able Insurance Services Ltd."

We reserve the right to amend or modify this Privacy Statement at any time and in response to changes in applicable law.

The Data Controller is Able Insurance Services Ltd (registered number Z5299812). Gladiator is a trading name of Able Insurance Services Ltd. At all times Able Insurance Services Ltd will remain the ultimate data controller. In this Privacy Statement "we," "us" and "our" means Able Insurance Services.