About honcho – who we are

We’re honcho and we’re on a mission to put the consumer back in control of how you buy insurance. This is our privacy policy for www.gethoncho.com, the honcho app and website(s) and Honcho Markets Ltd. The Financial Conduct Authority (FCA) authorise and regulate us under number 791467. Our company registration number is 09190148 and our registered address is Sandgate House, 102 Quayside, Newcastle Upon Tyne, England, NE1 3DX. With respect to the General Data Protection Regulation (GDPR), we are the data controller of the personal data that you submit via the Website and the honcho app.

We’re also registered with the Information Commissioners Office (ICO) under registration number ZA085568.

We are passionate about protecting your privacy and the security of the personal data we hold, and process, on your behalf. This Privacy Policy explains how we collect information, what we use the information for, our legal basis for doing so, and what controls you have. If you have any questions about how our handling of your personal information you can email us at privacy@honchomarkets.com

From time to time this privacy policy will need to be changed and we reserve the right to do this. We will publish any updated versions on our website and the date this policy was last updated can be found at the bottom of this page.

What information do we collect from you?

If you are a honcho customer:

Information you give to us - we may collect and process the following personal information about you or any other person you submit information on behalf of (e.g. an additional driver). By giving us information about another person, you are confirming that you have ensured they are aware of our Privacy Policy and you have their consent to do this:

General personal details, which may include:

Account sign-in information, which will include the following as set by you:

Details in relation to requests for bids, which may include:

Communications you send to us (by telephone, email or otherwise), for example, to report a problem or to submit queries, concerns or comments regarding the Website, our service, or general comments.

If you are an Insurer:

Information you give to us - we may collect and process the following personal information about you and your firm:

General personal details, which may include:

Account sign in information:

Information about your company:

Communications you send to us (by telephone, email or otherwise), for example, to report a problem or to submit queries, concerns or comments regarding the Website, our service, or general comments.

Information we collect about you

Each time you visit the App or Website we may automatically collect the following information:

We may receive information about you if you use any other websites we operate or other services we provide.

The information detailed above will not constitute personal data.

What we do with your data?

If you are an insurer: we need to process your data in order to maintain your membership with honcho and ensure you can use the app and make bids.

If you are a customer: we use your personal data for the following purposes:

Providing our services to you We need to process certain personal information to provide our services to you, which includes providing bids from insurers for insurance policies. To deliver our services, your personal data may also be transferred to the following third parties:

The legal basis for us and our business partners to process your data is known in legal terms as the performance of the contract for provision of the services.

Contacting you about our services If you have given us your contact information, we may use these details to get in touch with you about the services we offer. For example, this might be to check if we can help you finish off an incomplete registration or to email you details of offers you may be interested in.

You can opt out of this at any time either by clicking “Unsubscribe” in the footer of our emails to you or by contacting us at privacy@honchomarkets.com

Improving our services To improve our services, we may ask for your feedback via our App and website. We may then share this with other honcho users to enhance the honcho experience for everyone.

Customer Support and account administration We may use your personal data to provide you with customer support or to investigate a complaint or concern that you may have about your account

Related products and services We may from time to time recommend certain third-party products and services to you if they complement the honcho experience.

Our lawful basis for processing your personal data

By now you’ve probably heard lots about (and had loads of emails about!) the EU General Data Protection Regulation (GDPR); well under Article 6 of the GDPR we are required to tell you the legal basis under which we collect and process your data.

If you are an insurer:

We will only collect and process your personal data in accordance with the below lawful basis:

If you are a customer:

We will only collect and process your personal data in line with one of the below lawful bases:

For important (but boring) reasons, under Article 6 of the EU General Data Protection Regulation (GDPR) we need to tell you about the legal basis under which we collect and process special category data, we also need to satisfy a specific condition under Article 9 of the GDPR. Under Article 9 of the GDPR, health information is considered special category data.

As mentioned above, for us to provide you with a relevant bid, we may collect information about your health or criminal convictions (both motor and non-motor related). A specific condition under Article 9 (2) of the GDPR is the following:

“the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject”.

Therefore we will ask for your explicit consent to the processing of the data about your health. We will never assume that we have your consent unless you have explicitly opted in. We will ask you to give your consent in the relevant part of your journey through our app or website. You can withdraw your consent at any time by contacting us at privacy@honchomarkets.com. Please note that if you withdraw your consent we may not be able to provide you with bids.

Data storage and international transfers

We take the security of your data very seriously, and all your personal data will be kept according to strict safeguards and in compliance with the GDPR. Your data will be stored on cloud servers within the UK and we will only store your data outside the UK when the jurisdiction in question has been assessed as compliant with the GDPR.

Automated decision-making

When you enter in your personal and insurance details to obtain an initial bid using the honcho app, our technology uses this to automatically find products that might meet your needs. This does not affect your legal rights.

Your rights

You have the right to be informed over what personal data we hold and how we are using it. This information is contained within this privacy policy.

If you have consented to particular uses of your personal data, you have the right to withdraw this consent at any time.

You have the right to “portability” of your personal data that we have collected with your consent or in performance of a contract. This means that you can request copies of all the personal data we hold for this purpose in a structured, commonly used, and machine-readable form, and we will supply this to you free of charge on request. We will respond to these requests within 30 days, unless the request is particularly complex, in which case we will inform you of how long it will take as soon as possible.

You have the right to request a copy of the personal data we hold under the GDPR by making a “subject access request” to us in writing. We will comply with all valid subject access requests within 30 days, unless the request is particularly complex; in this case we will contact you within 30 days with further information. You will not be charged for making a subject access request unless we reasonably deem this to be an obviously unfounded or excessive request, in which instance you will be charged a reasonable fee based on the administrative costs of providing the information.

If some of the personal data we hold is inaccurate or incomplete, you can request that we rectify our records by writing to us. We will comply with all requests within 30 days unless the request is particularly complex; in this case we will contact you within 30 days with further information.

Where we are using your personal data in accordance with our legitimate interests, you can object to further use of your data. This objection should be based on grounds relating to your particular situation. If you object, we will stop using your personal data in this way immediately, unless there are compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms (such as requests by law enforcement) or we need to process your data for the establishment, exercise or defence of legal claims. You may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails.

You have the right to request erasure of the personal data we hold by contacting us. Please note that it is not always possible for us to comply with a request for erasure; for example, if we have collected data from you in performance of a contract, we cannot normally comply with a request for erasure unless we no longer have an active contract with you and the data is more than six years old.

You have the right to restrict the processing of your personal data in certain circumstances, such as when you object to us using your data in accordance with our legitimate interests or when you contest the accuracy of the data we hold on you.

You can exercise any of your rights by contacting us via email at privacy@honchomarkets.com. Please note that we may need to verify your identity before complying with any of the above requests.

How long we will keep your data for

We will only keep your personal data for as long as is necessary. This means that we will retain your personal data for as long as we have an active contract or business relationship with you, and after this, we will only keep your data for as long as is necessary for the purposes which it is stored. Any data shared with our business partners, which include insurance providers and insurance intermediaries, for the purpose of getting you bids will be deleted after a maximum period of 28 days post you clicking ‘Get bids’. If you buy a policy via honcho, the insurer that you buy from will not delete your data after 28 days as they will need to keep it in order to maintain your contract of insurance.

We also use 3rd party providers as part of getting you insurance bids, some of those require that you contact them directly to have your data deleted.
These companies are:

What happens if you don’t provide us with the information we need

As outlined above, some of the personal data you provide to us will be used to enter into a contract with you and to comply with our legal obligations. Should you not provide us with the data we require to offer our service or request that we erase the personal data we hold, it is likely that we will not be able to deliver our services to you.

Complaints

If you feel that we have not been complying with our obligations on data protection law or you wish to assert one of your rights, please contact us without delay by emailing us at complaints@honchomarkets.com Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO). Contact details for the ICO can be found on this webpage https://ico.org.uk/global/contact-us/

Last updated 30th November 2018.