Privacy Policy

This privacy policy applies between you, the User of this Website and CDR Insurance Services Limited, the owner and provider of this Website. CDR Insurance Services Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

Purpose

This Privacy Notice explains how CDR Insurance Services Limited ("CDR") collects, uses, stores, and protects personal data.

CDR is committed to handling personal data in a lawful, transparent, and secure manner, in accordance with:

• UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018
• FCA requirements and expectations

This notice applies to all clients, prospective clients, and individuals whose personal data is processed by CDR.

Who We Are

CDR Insurance Services Limited is an insurance intermediary providing advice and arranging commercial insurance products.

CDR operates as an Appointed Representative of Momentum Broker Solutions Ltd, which is authorised and regulated by the Financial Conduct Authority (FCA).

As an Appointed Representative, CDR operates under the regulatory oversight of Momentum Broker Solutions Ltd. Where required, Momentum may also process personal data in relation to regulated activities, including compliance, oversight, and regulatory reporting.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

   Data	collectively all information that you submit to CDR Insurance Services via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
   Cookies	a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
   Data Protection Laws	any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
   GDPR	the General Data Protection Regulation (EU) 2016/679;
   CDR Insurance Services Limited, we or us	CDR Insurance Services Limited of 3 Salmons Leap, Calne, Wiltshire, SN11 9EU;
   UK and EU Cookie Law	the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
   User or you	any third party that accesses the Website and is not either (i) employed by CDR Insurance Services and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to CDR Insurance Services and accessing the Website in connection with the provision of such services; and
   Website	the website that you are currently using, www.cdrinsurance.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:
   1. the singular includes the plural and vice versa;
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
   3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
   4. "including" is understood to mean "including without limitation";
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

1. This privacy policy applies only to the actions of CDR Insurance Services and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
2. For purposes of the applicable Data Protection Laws, CDR Insurance Services is the "data controller". This means that CDR Insurance Services determines the purposes for which, and the manner in which, your Data is processed.

Data collected

1. We may collect the following Data, which includes personal Data, from you:
   1. demographic information such as postcode, preferences and interests;
   2. IP address (automatically collected);
   3. web browser type and version (automatically collected);
   4. operating system (automatically collected);
   5. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
   in each case, in accordance with this privacy policy.

How we collect Data

1. We collect Data in the following ways:
   1. data is given to us by you; and
   2. data is collected automatically.

What Personal Data We Collect

We collect only the personal data necessary to provide our services.

• Identification details (name, address, date of birth)
• Contact details (email address, telephone number)
• Business and risk information relevant to insurance placement
• Financial information where required
• Claims history and insurance records
• Communications and correspondence

We ensure that personal data collected is limited to what is necessary, relevant, and proportionate for the purposes for which it is processed.

Data that is given to us by you

1. CDR Insurance Services will collect your Data in a number of ways, for example:
   1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
   2. when you elect to receive marketing communications from us;
   in each case, in accordance with this privacy policy.

Data that is collected automatically

1. To the extent that you access the Website, we will collect your Data automatically, for example:
   1. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
   2. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
   3. we use Google Analytics (a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to collect information about how you interact with our Website. Google Analytics stores information such as the pages you visit, the time you spend on the Website, how you arrived at the Website, and what you click on. Your IP address is also recorded by Google Analytics. Google Analytics places cookies on your device. For further information about how Google Analytics collects and uses data, please visit Google's Privacy Policy. Analytics cookies are only placed on your device if you have consented to analytics tracking via our cookie consent banner.

How we use Personal Data

We use personal data to:

• Provide insurance advice and recommendations
• Arrange and administer insurance policies
• Obtain quotations from insurers
• Manage renewals and mid-term adjustments
• Handle claims and support client enquiries
• Meet legal and regulatory obligations
• Prevent fraud and financial crime

Personal data is processed only for legitimate business purposes.

Lawful Basis for Processing

We process personal data under the following lawful bases:

• Contract - to provide insurance services requested by clients
• Legal obligation - to meet regulatory and compliance requirements
• Legitimate interests - to conduct and improve our business operations

Where we process special category (sensitive) personal data (for example, health information), this will be done only where necessary and in accordance with UK GDPR requirements. Where required, we will obtain explicit consent.

Sharing Personal Data

We may share personal data with:

1. insurers and product providers
2. our principal firm, Momentum Broker Solutions Ltd
3. third-party service providers where necessary to provide our services and meet regulatory obligations

All third parties are required to handle data securely and in accordance with applicable data protection laws.

We do not sell personal data.

Data Security

CDR takes appropriate technical and organisational measures to protect personal data, including:

• Secure cloud-based systems (e.g. Microsoft 365, Acturis)
• Password protection and multi-factor authentication
• Restricted access based on business need
• Regular monitoring and review of systems

These measures are reviewed regularly to ensure they remain appropriate to the size, nature and complexity of our business.

Data Retention

Personal data is retained only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, accounting, and insurance-related requirements.

In most cases, personal data will be retained for at least 6 years from the end of the client relationship, although longer retention periods may apply where required.

This approach helps ensure that records are available where needed to support ongoing obligations, resolve queries or complaints, and meet applicable legal or regulatory requirements.

Our use of Data

1. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
   1. transmission by email of marketing materials that may be of interest to you;
   in each case, in accordance with this privacy policy.
2. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
3. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
   1. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
   2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
   3. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

Who we share Data with

1. We may share your Data with the following groups of people for the following reasons:
   1. our employees, agents and/or professional advisors - to help us provide our services to you and to help us run our business;
   2. third party service providers who provide services to us which require the processing of personal data - to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website runs smoothly; in accordance with this privacy policy.

Keeping Data secure

1. We will use technical and organisational measures to safeguard your Data, for example:
   1. access to your account is controlled by a password and a user name that is unique to you.
   2. we store your Data on secure servers.
2. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected].
3. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

1. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
2. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

Individuals have the right to:

• Access their personal data
• Request correction of inaccurate data
• Request deletion (where appropriate)
• Restrict or object to processing
• Request data portability

Requests should be made in writing using the contact details below.

Complaints and ICO

If you have concerns about how your data is handled, please contact CDR in the first instance.

If you are not satisfied with how we have handled your data, you have the right to complain to the Information Commissioner's Office (ICO):

Website: https://www.ico.org.uk

Contact Details

The Directors
CDR Insurance Services Limited
Email: [email protected]
Registered Office: 3 Salmons Leap, Calne, Wiltshire, SN11 9EU

Transfers outside the European Economic Area

1. Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. This includes data processed by Google Analytics, which may transfer data to the United States of America.
2. We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, such as:
   1. data transfer agreement incorporating the standard contractual clauses adopted by the European Commission;
   2. adequacy decisions recognising equivalent data protection in the recipient country;
   3. contractual commitments from third parties such as Google's commitment to meet UK/EU data protection requirements.
3. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to other websites

1. Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

1. CDR Insurance Services may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of CDR Insurance Services. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
2. We may also disclose Data to a prospective purchaser of our business or any part of it.
3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

1. This Website may place and access certain Cookies on your computer. CDR Insurance Services uses Cookies to improve your experience of using the Website. CDR Insurance Services has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
2. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling CDR Insurance Services to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
4. This Website may place the following Cookies:

1. You can find a list of Cookies that we use in the Cookies Schedule.
2. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
3. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
4. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
5. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
4. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

1. CDR Insurance Services reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact CDR Insurance Services by email at [email protected].

Cookies

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Analytical/performance

We use the following analytical/performance cookies:

These cookies are only set after you have accepted analytics tracking through the cookie consent banner.