Privacy Notice

The website “policyadmin.co.uk” is operated by Policy Administration Services Limited, a member of the Phones 4u group of companies ( “we”, “us”, “our” or “company”). Policy Administration Services Limited is the controller of your personal information.

This Privacy Notice (“Notice”) describes how we will process and protect information relating to you (“Personal Information”). Your Personal Information shall be held and used in accordance with applicable legislation relating to the protection of Personal Information.

Douglas Nigel Rackham and David James Kelly have been appointed as Joint Administrators of Policy Administration Services Limited to manage its affairs, business and property as agents without personal liability.

All are licensed in the United Kingdom to act as insolvency practitioners by the ICAEW.

The Joint Administrators may act as Data Controllers of personal data as defined by UK data protection law depending upon the specific processing activities undertaken. PricewaterhouseCoopers LLP may act as a processor on the instructions of the joint administrators. Personal data will be kept secure and processed only for matters relating to the joint administrators’ appointment. Further details are available in the privacy statement on the PwC.co.uk website or by contacting the joint administrators.

Further details are available in the privacy statement at https://www.pwc.co.uk/who-we-are/privacy-statement/insolvencies-and-restructuring.html or by contacting the Joint Administrators via email at pas.enquiries@uk.pwc.com

The Joint Administrators are bound by the Insolvency Code of Ethics which can be found at: https://www.gov.uk/government/publications/insolvency-practitioner-code-of-ethics

1. How we collect your Personal Information

We collect your Personal Information:

when you contact us about your policy by phone, letter, email, our website, or through social media, and

while monitoring our technology tools and services, including this website.

2. The Personal Information we collect about you

The Personal Information we process includes:

Your personal information – such as name and date of birth

Contact information – such as home address, email address, phone number(s);

Policy information – such as:
  - Details of your mobile phone – such as make, model, serial number
  - Details of insurance claims – such as incident date, circumstances, fulfilment address, details of police reports
  - Other information you provide to us – such as letters and email communications sent to us.

3. How we use your Personal Information

We process your Personal Information for the following purposes:

As required by us to conduct our business and pursue our legitimate interests, in particular:

administering your insurance policy (for example updating your personal details, the details of your mobile phone or cancelling your policy);

fulfilment of insurance claims which have been assessed and accepted, and delivery of a repaired or replacement device to you;

in connection with legal claims (for example, relating to denial of an insurance claim), compliance, regulatory and investigative purposes (for example, theft and fraud investigations) as necessary (including disclosure of such information in connection with legal process or litigation);

to respond to any comments or complaints you send us;

to investigate complaints received from you or from others, about our products, the website or our services;

in response to demands or requests by regulators, governments, courts or law enforcement authorities; and

to provide management reporting information to enable us to assess trends and assist in improving our processes.

To provide you with important notices and updates, such as changes to our terms and policies, security alerts and administrative messages.

For purposes which are required by law:

Responding to complaints where we are under a legal or regulatory obligation to adhere to a complaints handling procedure; and

Fraud prevention purposes and other legal and regulatory obligations.

4. The basis on which we use your Personal Information

Data privacy laws set out a number of different reasons on which we may rely to collect and use your Personal Information. We use your Personal Information for the following reasons:

To comply with legal and regulatory obligations.

For legitimate business purposes. Using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalised to you, and to make your experience of our products and services efficient and effective.

To perform a contract to which you are a party: we may need to process your personal information to provide a product or service you request.

For the establishment, exercise or defence of legal claims or proceedings.

5. Sharing your Personal Information

5.1 Sharing personal information with our service providers

We employ third party companies and individuals to help provide our services to you (for example, customer support, application or database hosting, development, logistics). In particular, we will share your Personal Information with Lifestyle Services Group Limited, who provide insurance administration and associated services to us. These third parties have limited access to your Personal Information to perform these tasks on our behalf. The personnel of such third parties who use your Personal Information is limited to those individuals which are authorised to do so on a need-to-know basis and as necessary to provide these business services to us. We do not authorise such third parties to disclose or use this Personal Information for other purposes.

5.2 Disclosure to public authorities

We disclose your Personal Information to courts, regulators, governments and law enforcement authorities, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

5.3 Other categories of recipients

We may disclose your Personal Information, in the context of the sale of part or all of our business, an acquisition or where required by law, such as in the context of litigation or to comply with a court order.

We may also disclose your Personal Information to our professional advisers and auditors.

6. Transfers of your Personal Information outside of your home country

In providing our services to you, Personal Information may be transferred to, and processed in, countries where data protection and privacy regulations do not offer the same level of protection as the European Economic Area. These countries include the United States of America.

We will implement appropriate measures to ensure that your Personal Information remains protected and secure when it is transferred outside of your home country, in accordance with applicable privacy laws. These measures include data transfer agreements implementing standard data protection clauses. You can fine more information about data transfer agreements here.

7. Your choices and rights
You may have the right to:

ask us about the processing of your Personal Information, including to be provided with a copy of your Personal Information;

request the correction of, and/or deletion of your Personal Information;

request the restriction of the processing of your Personal Information;

request and the receipt or transmission to another organisation, in a machine-readable form, copy of Personal Information that you have provided to Us for a contract or with your consent, or to ask Us to transmit (port) this Personal Information to another controller; and

You may also object to our processing of Personal Information in certain circumstances (in particular, where we do not need to process the information to meet a contractual or other legal requirement (see section 4)

Where you are given the option to share your Personal Information with us, you can always choose not to do so.

If you object to the processing of your Personal Information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in section 4 or that you are unable to make use of the services and products offered by us.

You can exercise any of your rights by contacting us. In order to safeguard your Personal Information from unauthorised access, we may ask that you provide sufficient information to identify yourself prior to providing access to your Personal Information.

If you have unresolved concerns, or if you have suffered as a result of unlawful processing of your Personal Information, you have the right to complain to the UK Information Commissioner.

8. How long we keep your Personal Information

We will always keep your Personal Information for the period required by law and where we need to do so in connection with legal action or an investigation involving Policy Administration Services Limited. Otherwise, we keep your Personal Information:

for as long as needed to provide you with access to services you have requested; and

where you have contacted us with a question or request, for as long as necessary to allow us to respond to your request.

We may anonymise your Personal Information so that it can no longer be used to identify you. Once Personal Information is anonymized, we may retain and use such information, including after we have finished providing services to you. Additionally, we maintain logs and backups for security, debugging, and site stability purposes for up to 30 days after we have finished providing services to you.

9. How we secure your Personal Information

We have implemented safeguards designed to protect your Personal Information in accordance with industry standards.

We have measures in place to restrict access to Personal Information to those individuals whom we know have a valid business purpose to have access to such information. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the Personal Information submitted to us, both during transmission and once we receive it. We require those who provide services for us to keep such information secure and confidential. However, no method of transmission over the internet or method of electronic storage is totally secure. Therefore, we cannot guarantee its absolute security.

10. Important information

10.1 Minimum age

We do not knowingly collect Personal Information from anyone under the age of 18. You must be at least 18 years of age to use the“policyadmin.co.uk” website.

10.2 Changes to this Notice

We may update this Notice from time to time. If We make any material changes to this Notice, we will notify you by means of a notice through this website, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use our services. We encourage you to review changes carefully.

10.3 Contact Us

We welcome your questions or comments regarding this Notice. If you have questions or requests about the processing of your personal information, or need additional information, you can contact our Data Protection Officer at:

Policy Administration Services Limited
Data Protection Officer
Central Square, 8th Floor
29 Wellington Street
Leeds LS1 4DL
United Kingdom

You can also send us an email to relations@policyadmin.co.uk

Effective date: April.2020

Cookie Notice

We do not use cookies or other online tracking devices (such as web beacons, action tags, local shared objects (‘flash cookies’) on our website.

This Cookie Notice should be read in conjunction with our Privacy Notice If you have any questions or concerns about the Cookies Notice or its implementation you may Contact us

Effective date: April.2020