About us

In this Privacy Agreement references to “we” or “us” or “SPM” or “Sapphire Pest Management” are to Sapphire Pest Management.

We are the data controller of any personal information you provide to us. This means that we are responsible for complying with data protection laws as set out in the Data Protection Act 2018 . This Privacy Agreement describes what personal information we may collect from you, why we use your personal information and more generally the practices we maintain and ways in which we use and protect your personal information.

If you have any questions about how we collect, store or use your information, you can contact our data protection officer using the details set out in “Contacting us”.

Who do we collect information about?

  • Previous, current and prospective customers
  • SPM website users
  • Business contacts at our customers and other suppliers

When do we collect personal information?

  • When you apply for a service (e.g. by telephone, email or when you submit a request for a quotation), whether you complete that fully or not.
  • When you renew a contract
  • Whenever you use the SPM website
  • If you respond to a customer survey, questionnaire, or marketing campaign
  • If you contact us for any other reason
  • From publicly available third-party sources such as credit rating databases and government databases for socio-demographic information
  • When you contact us through our “refer a friend” scheme

In order for us to provide quotes and service contracts, and to deal with any claims or complaints, we need to collect and process personal data about you.

The personal information that we collect will depend on your relationship with us. We will collect different information depending on whether you are a contract holder or prospective customer; beneficiary under a contract; or website user, broker, advocate or other third party.

Please note: in certain circumstances we may request and/or receive ‘sensitive’ data, also known as ‘special categories’ of personal information about you. For example, we may need access to details of any person classed as being part of a “vulnerable group” (e.g. elderly, children) to assistant our staff when visiting your property or place of work.

If you provide personal information to us about other individuals (for example, when you submit a quotation request) you agree: (a) to inform the individual about the content of this Privacy Agreement; and (b) to obtain any consent where we indicate that it is required for the processing of that individual’s personal data in accordance with this Privacy Agreement. Please check the relevant section below for detailed information regarding the types of personal information we are likely to collect and use about you.

Personal information:

  • General information such as your name, address, address of the property or business being serviced, contact details, date of birth, gender, family and relationship information,
  • Information about your job including job title, employment history, education history (job application), and professional accreditations
  • Information relevant to your request for a quotation for a service. This will depend on the nature of the service but could include details of your property or business activities
  • Information relevant to your request or your involvement in the matter giving rise to a service being agreed
  • Information relating to previous quotations, or services
  • Financial information such as your bank details, credit card and payment details, bankruptcy and company directorship information, and information obtained as a result of our credit checks and those carried out by third parties such as a credit provider
  • Information obtained through our use of cookies. You can find more information about this in our Cookie Agreement
  • Website browsing history
  • Information captured during our telephone calls, whether inbound and outbound
  • Your marketing preferences
  • IP address
  • Device ID information

Sensitive personal information:

  • Information relating to criminal history (including offences and alleged offences and any caution, court sentence, or criminal conviction) which are required if apply for a position with SPM

How do we collect your information?

We collect personal information from several different sources, including:

  • Directly from you or from someone else on your behalf
  • From introducers, partners, and MGAs (managing general agents)
  • From other third parties involved in your service contract or job agreement
  • From other third parties who provide a service in relation to your service agreement
  • Through publicly available sources such as internet search engines and social media sites
  • Through customer surveys and responses to various marketing campaigns
  • From your use of our website and its cookies – please see our Cookie Policy
  • From inbound and outbound phone calls
  • From credit reference agencies
  • Through fraud prevention and detection databases and sanctions screening tools
  • From government agencies such as HMRC and from professional regulators

SPM has internal agreement documents in place to ensure that any information used that’s in the public domain or sourced from social media sites is used in line with our usual obligations.

What are the purposes for which your information is used?

We may process your personal information for a number of different purposes. For each purpose we must have a legal ground for such processing. When the information we process is classed as sensitive personal information, we must have an additional legal ground for such processing.

Generally, we will rely on the following legal grounds:

  • Where the processing is necessary for our provision of your service agreement and services for activities such as assessing your application, managing your agreement, handling enquiries, and providing other services to you
  • Where we have an appropriate business need such as maintaining our business records or developing and improving our products and services where such business need does not harm your interests
  • Where we have a legal or regulatory obligation to use such personal information
  • Where the use is necessary to establish, exercise, or defend our legal rights
  • Where you have provided your consent to our use of your personal information

You will find details of our legal grounds for each of our processing purposes below.

To set you up as a service customer, including carrying out fraud, credit, and anti-money laundering checks

Legal grounds:

  • This processing is necessary for providing and administering your service contract

Additional legal grounds for processing sensitive personal information:

  • There are, however, several safeguards. The most important is that the processing must be “necessary” for the service process
  • In addition, it must also be necessary for reasons of substantial public interest (i.e. because it is necessary for the purposes of preventing fraud)

To evaluate your service application and provide a quote; this might include us calling you after you submit a request for quotation form so that we can deal with any queries or questions around the quotation process

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests
  • This processing is necessary for our providing your service contract

Additional legal grounds for processing sensitive personal information:

  • If required, we have asked and you have provided your explicit consent. It might be that we need your consent for this activity in order to provide you with your service under the contract, but we will make this clear when we ask for your consent

General administration of agreements (general client care, including communicating with you regarding administration and requested changes to the service agreement, and sending you updates regarding your service agreement)

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests
  • This processing is necessary for providing your service agreement. We will need your consent for this activity in order to provide you with service under the contract

Additional legal grounds for processing sensitive personal information:

  • If required, we have asked and you have provided your explicit consent. It might be that we need your consent for this activity in order to provide you with service under the agreement, but we will make this clear when we ask for your consent

Claims processing

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests
  • This processing is necessary for providing your service agreement. We will need your consent for this activity in order to provide you with service under the agreement

Additional legal grounds for processing sensitive personal information:

  • If required, we have asked and you have provided your explicit consent. It might be that we need your consent for this activity in order to provide you with service under the agreement, but we will make this clear when we ask for your consent

Management of complaints (including communicating with you and resolving any complaints that you might have)

Legal grounds:

  • This processing is necessary for providing your service contract
  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Additional legal grounds for processing sensitive personal information:

  • If required, we have asked and you have provided your explicit consent. It might be that we need your consent for this activity in order to provide you with service under the agreement, but we will make this clear when we ask for your consent

Complying with our legal or regulatory obligations

Legal grounds:

  • The use is necessary in order for us to comply with our legal obligations

Additional legal grounds for processing sensitive personal information:

  • If required, we have asked and you have provided your explicit consent. It might be that we need your consent for this activity in order to provide you with service under the agreement, but we will make this clear when we ask for your consent

Providing improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers)

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Additional legal grounds for processing sensitive personal information:

  • If required, we have asked and you have provided your explicit consent. It might be that we need your consent for this activity in order to provide you with service under the agreement, but we will make this clear when we ask for your consent

Managing our business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, and receiving professional advice (e.g. tax or legal advice)

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Provide marketing information to you (including information and marketing campaigns about our other products and services), in accordance with any preferences* you have expressed

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests
  • Where you have provided your consent to our use of your personal information
  • Please see “what marketing activities we carry out” for further information, and please see *The right to object to marketing.

Monitoring applications, reviewing, assessing, tailoring, and improving our products and services and similar products and services offered by SPM

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Offering renewal on the expiry of your agreement

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Additional legal grounds for processing sensitive personal information:

  • If required, we have asked and you have provided your explicit consent. It might be that we need your consent for this activity in order to provide you with service under the agreement, but we will make this clear when we ask for your consent

Tracing and re-servicing debt

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Monitoring usage of any of the various SPM websites

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Ensuring that content from our site is presented in the most effective manner for you and for your device

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Allowing you to participate in interactive features of our services, when you choose to do so

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Investigating or detecting the unauthorised use of our systems, to secure our system and to ensure the effective operation of our systems

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Other purposes outside of the company lifecycle but necessary for the provision of service throughout the agreement lifecycle period (including, among other things, general risk modelling, transferring books of business, any change in ownership of the company (whether in whole or part), and re-organisations)

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Carrying out customer research and customer insight exercises to understand our customers needs, to help us to improve and monitor our services and products

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Ad-hoc communications and fulfilment of thank you notes, gifts, and other vouchers

Legal grounds:

  • Us having an appropriate business need to use your information which does not cause any harm to your interests

Who do we share your information with?

From time to time we may share your personal information within the SPM group, which is part of and with carefully vetted third parties. If you would like further information regarding the disclosures of your personal information, please see the details listed below. If you have further questions, please see section 14 for our contact details.

Disclosures to third parties

We also disclose your information to the third parties listed below for the purposes described in this Privacy Policy. These might include:

  • Our insurance partners such as other insurance intermediaries, insurers, reinsurers, introducers, or other companies who act as insurance distributors
  • Insurance reference bureaus
  • Other third parties who assist in the administration of service agreements, accountants, auditors, lawyers, and other experts
  • Fraud detection agencies and other third parties who operate and maintain fraud detection registers
  • Our regulators
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime
  • Other insurers who provide our own insurance
  • Industry bodies
  • Debt collection agencies
  • Credit reference agencies
  • Online search engines
  • Social media platforms
  • Our third party service providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, payment processing agencies, document management providers, and tax advisers
  • Third parties who undertake analysis for the purposes of product improvement
  • Selected third parties in connection with the sale, transfer, or disposal of our business. We will ensure that such third parties have the appropriate technical and organisational measures in place to safeguard your data

International payments

We (or third parties acting on our behalf) may store or process information that we collect about you in countries outside the European Economic Area (EEA). Where we make a transfer of your personal information outside of the EEA we will take the required steps to ensure that your personal information is protected. We do this by using the EEA approved standard contractual clauses. If you would like further information regarding the steps we take to safeguard your personal information, please contact us using the details set

What marketing activities do we carry out?

Marketing activities

Email marketing

We may also use your personal information to provide you with information by email about our products or services or those of our partners which may be of interest to you or to send eNewsletters. You have the option to opt out at any time.

If you wish to unsubscribe from emails sent by us, you may do so at any time by clicking on the “unsubscribe” link that appears in all emails. Otherwise you can always contact us using the details set out in below to update your contact preferences, or email info@sapphire-pm.com In such circumstances, we will continue to send you service-related (non-marketing) communications where necessary.

SMS marketing

We may also use your personal information to provide you with information by text message about our products or services or those of our partners which may be of interest to you. You have the option to opt out at any time.

You can stop receiving text messages sent by us at any time by following the instructions in the text message on how to unsubscribe. This appears in all text messages. Otherwise you can always contact us using the details set below to update your contact preferences. In such circumstances, we will continue to send you service-related (non-marketing) communications where necessary.

Telephone marketing

We may also use your personal information to call you regarding products and services you have expressed an interest in, or which we believe may be of interest to you. You can opt out of receiving these calls at any point.

You can stop receiving telephone calls from us at any time by contacting us using the details set out below to update your contact preferences. In such circumstances, we will continue to send you service-related (non-marketing) communications where necessary.

Post

We may also use your personal information to provide you with information by post about our products or services or those of our partners which may be of interest to you. You have the option to opt out at any time.

You can stop receiving post from us at any time by contacting us using the details set out below to update your contact preferences. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary.

TO STOP receiving any marketing communications from us please email info@sapphire-pm.com

If you have been referred to us through one of our partner’s websites

We will only use your personal information to contact you about our products or services, or those of our partners which may be of interest to you, if our partner has provided us with your consent, indicating that you are happy for us to contact you using one of the methods set out above. You have the option to opt out at any time (please see above).

How long do we keep personal information for?

We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply with our legal, statutory, and regulatory obligations – in particular, for so long as there is any possibility that either you or we may wish to bring a legal claim under the insurance policy, or where we are required to keep your personal data due to legal or regulatory reasons. If you would like further information regarding the periods for which your personal information will be stored, please see below for our contact details.

Your rights

Under data protection law you have certain legal rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out below.

Please note:

  • In some cases we may not be able to comply with your request (e.g. we might not be able to delete your data) for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make, and if we can’t comply with your request we will tell you why
  • In some circumstances exercising some of these rights (including the right to erasure, the right to restriction of processing, and the right to withdraw consent) will mean we are unable to continue providing you with service under the agreement and may therefore result in the cancellation of the contract. You will therefore lose the right to bring any claim or receive any benefit under the agreement, including in relation to any event that occurred before you exercised your right of erasure, if our ability to handle the claim has been prejudiced. Your agreement terms and conditions set out what will happen in the event your contract is cancelled
  • For some agreements no refunds will be payable on cancellation, for other products a refund may be payable

Your rights include:

1. The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your information will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible.

2. The right to rectification

We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.

3. The right to erasure (also known as ‘the right to be forgotten’)

In certain circumstances, you have the right to ask us to erase your personal information. Examples would include where the data is no longer required for the original purpose, consent has been withdrawn and there no overriding grounds for continuing the processing, or for compliance with the national law or for legal or regulatory obligations. There are occasions when a request made under data protection law is overridden by other legal and statutory data retention requirements.

4. The right to restriction or suspension of processing

In certain circumstances, such as a question over its accuracy, you are entitled to ask us to stop using your personal information or to suspend its use.

5. The right to data portability

In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice.

6. The right to object to marketing

You can ask us to stop sending you marketing messages at any time. To STOP receiving all marketing communications from us please email info@sapphire-pm.com

7. The right to object to processing

For certain uses of your personal information, we will ask for your consent. This consent can take the form of an action or affirmative instruction. Where we do this, you have the right to withdraw your consent to further use of your personal information. In other circumstances we may process your data using legitimate interest, and again you have the right to withdraw this right of processing, unless it is necessary in connection with our legal rights.

Please note that in the event that you withdraw your permission for us to use all of your personal data, we may be unable to continue providing you with service under the agreement and this may therefore result in the cancellation of the contract. You will therefore lose the right to bring any claim or receive any benefit under the contract. Your contract terms and conditions set out what will happen in the event your contract is cancelled.

The right to lodge a complaint with the ICO

We would hope that you will always raise any issues with us first, and that we will be able to resolve them to your satisfaction. However, if this isn’t possible then you always have a right to complain directly to the Information Commissioner’s Office (ICO) if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations.

Please see below for contact details of the ICO:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

Email: casework@ico.org.uk

Making a complaint will not affect any other legal rights or remedies that you have.

How we protect your information

We use a wide range of organisational and technical security measures to protect your information. This includes regular and thorough staff training about data security and data rights.

Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and to use a password that is appropriate (i.e. a mixture of upper and lower case letters, and characters, which isn’t used on other sites and isn’t easily guessed).

We restrict access to your information as appropriate within Simply Business to only those who absolutely need to know that information for the purposes set out above.

Firewalls are used to block unauthorised traffic to the servers and the actual servers are located in a secure location which can only be accessed by authorised personnel. Our internal procedures cover the storage, access and disclosure of your information.

Contacting Us

If you have any questions about how we collect, store or use your personal information, you may contact our data protection officer at:

Sapphire Pest Management

132 Deans Way

Coventry

CV7 9HH

Email: info@sapphire-pm.com

Updates to this Privacy Policy

From time to time we will make changes to this Privacy Policy, for example as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally. You should check our website periodically to view the most up-to-date Privacy Policy.

This Privacy Policy was last updated on 13th August 2018.