Contact State Prospect Information Notice
This document was last updated on 28/04/2020.
We are Contact State Ltd. We work with insurance and finance providers (called 'providers' in this notice) and the operators of websites on which people register to hear more about those providers' products and services, including getting quotes (called 'marketing sites' in this document). We collect de-identified data from marketing sites and providers, and use it to indicate to providers indicate to us the likelihood that your request has been submitted by a 'real' human and not a robot, or automated quote request generator. We do this by examining a 'browser fingerprint' associated with your quote or contact request you make through the marketing site – it contains, for example, details of the model of device you are using, your Internet browser, and the region from which you submit your request. We retain that de-identified data and use it to help verify requests for info from a range of different providers and marketing sites. We are based in the UK and will not store your de-identified data outside the UK and European Union. When we say 'de-identified', we mean that we are unable to establish your identity from the data we receive. We don't receive your name, contacts details, or anything else that could reasonably identify you in the 'real world'.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as 'controller' of that personal information for the purposes of those laws.
Personal information we collect about you
We may collect and use the following personal information about you:
We generate a fingerprint which is derived from your IP address and browser settings, including your browser user agent, browser plugins, device, mouse and keyboard movement and screen dimensions.
We capture referrer data available to the browser which may include your path through the website Contact State is installed on.
We capture an irreversible “one way” SHA256 hash of the form data submitted so that we can look for patterns in submitted data. At no point in time do we capture plain text form data, and because of the nature of cryptographic hash functions, the transformation cannot be reversed to reveal the plain text.
How your personal information is collected
We collect this personal information from either direct from the marketing site from which you made your request for information, or else from providers (who have received it from that marketing site). We only collect this information when the "submit" button is clicked. We require the marketing site provider to show you a link to this notice before you submit your request for information.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so. In our case, the legal basis for processing your personal data is that it is necessary for the legitimate interest of us, you, providers and marketing sites. A "legitimate interest" is when there is a good business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Providers have a legitimate interest in establishing that requests for info on their finance or insurance products are a from a real person, not a robot. Marketing sites have a legitimate interest in assuring providers that this is the case. We have a legitimate interest in helping providers and marketing sites achieve those aims, and in doing so carrying out our own business of providing services to providers confirming that people requesting info from them are indeed 'real' potential customers, not robots.
We will never seek to establish your identity from the de-identified data we hold about you.
We will never be able to, or seek to, send you anything because we do not have your contact details.
We will never provide the de-identified data we have about you for use by any person other than providers and marketing sites, and people acting on their behalf, if they ask us to.
Who we share your personal information with
We share your de-identified personal information with marketing sites, and the providers who pay for our service.
We store your personal information with our hosting provider, Heroku Inc which is a Salesforce company.
We impose contractual obligations on our hosting provider to ensure they can only use your personal information to provide services to us. We may also share personal information with external auditors, and with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be de-identified but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
How long your personal information will be kept
We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the United Kingdom and European Economic Area (EEA), e.g. to a provider who is based outside the UK and EEA.
These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses please contact us at firstname.lastname@example.org.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object: — at any time to your personal information being processed for direct marketing (including profiling). Note that we are unable to do this in any event as we do not have any contact details for you; — in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.|
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, we will need to first understand whether we have any data about you. Because we don't have any contact details or other data identifying you as an individual, we rely on marketing sites to pass on requests - they are the ones who actually have the email address which corresponds to the de-identified data we hold about you. Please make your request to the marketing site from which you made your request for provider information, and we will action it.
Keeping your personal information secureObviously, one big security measure we take is not having any data about you that could be used to identify you. We also have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you (via the marketing sites) and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was last updated on 28/04/2020.
We may change this privacy notice from time to time—when we do, we will take steps to inform you via the marketing sites.
How to contact us