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Your privacy is important to Alliance Health PMI Limited t/a Kindred (“we”, “us”, “our”) and we are committed to respect and protect your privacy and your personal information. This privacy policy tells you what you can expect us to do with personal information we hold on you, what kinds of information we hold, how we receive it and who we receive it from. It explains who else we may share your information with, and gives you details about your data rights and how you may use them. It also describes how we comply with relevant data protection legislation including the Data Protection Act 2018 and the UK General Data Protection Regulation.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy notices and is not intended to override them.
This privacy policy is updated from time to time, to reflect any changes in how we use and handle personal information. This privacy policy was last updated August 2023.
This privacy policy relates to the following types of individuals, where we hold your personal information:
There are types of individuals who this privacy policy does not relate to, for example Alliance Health PMI Limited employees and sub-contractors (including prospective and former employees and sub-contractors), employees of our current, former or prospective business partners and service suppliers, and members of the press.
If you are one of these individuals and would like further information on how we collect, use and store your data, please contact our data protection representatives at:
Alliance Health PMI Limited is an insurance intermediary specialising in providing private health insurance.
Alliance Health PMI Limited is an Appointed Representative (AR) of Alliance Medical Indemnity Limited who are authorised and regulated by the Financial Conduct Authority (‘FCA’). Alliance Health PMI Limited’s FCA reference number is 952671. Alliance Medical Indemnity Limited is a limited company registered in England and Wales under company number 07655729 and has its registered office at 54 Hagley Road, Birmingham, England, B16 8PE. Its FCA reference number is: 831527. You can check this on the Financial Services Register on the FCA’s website at https://register.fca.org.uk.
Alliance Health PMI Limited is the controller and is responsible for deciding how your personal data will be processed.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the [DPO OR data privacy manager] by[6] email at compliance@kindred.co.uk
We collect personal data from you when:
We also collect your information from other third-party sources where we have legal grounds to do so. These include anti-fraud and crime-prevention agencies, credit reference and vetting agencies, analytics providers, advertising networks, search information providers, providers of technical payment services and other data providers.
Depending on your relationship with us, we may hold the following types of information about you:
Some of our processes combine different sets of information we hold. This can include combining different data sets we have about you or combining your information with that of other individuals.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your insurance policy or any other product or service you have with us but we will notify you if this is the case at the time.
How we use your personal information
We collect your information and use it in different ways depending on your relationship with us and how you have interacted with us. This can include information we share with or receive from other third parties.
We will only use your personal information when the law allows us to. Most commonly, we use your information for the following lawful reasons:
To enter into or perform a contract: for example, to provide a private health insurance quotation, to arrange and administer your insurance including making any changes, renewing your policy, cancelling your policy answering queries and to action your requests.
This information may also include sensitive (special category personal data) data such as your medical history and conditions which we can collect on grounds of substantial public interests to provide you with a quotation, arrange your insurance, administer your insurance, and/or administer a claim. If you give us information about another person in doing so you are confirming that you have their permission to do so and that we may use their personal data in the same way as we will use your personal data.
To comply with a legal obligation: for example the rules set by our regulator the Financial Conduct Authority (FCA), and The Financial Ombudsman Service, to fulfil your data rights under data privacy laws, handle complaints about data privacy or our insurance products and services and to comply with other legal requirements.
For our legitimate interests: for example to detect and prevent fraud, money laundering and other financial crimes, monitor and improve our business and our products and services, demonstrate compliance with applicable laws and regulations, handle legal claims, respond to other types of complaint not previously mentioned, and sending you postal direct marketing communications.
Where we rely on this lawful reason, we assess our business needs to ensure they are proportionate and do not affect your rights. In some instances, you also have the right to object to this kind of use. For more information, visit the “Your data rights” section of this policy.
With your consent: for example by sending you email marketing communications,. You can withdraw your consent at any time.
To protect vital interests: in extreme or unusual circumstances, we may need to use your information to protect your life or the lives of others.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To provide you with a quotation | (a) Identity (b) Contact (c) Information disclosed to the insurers of the policy and their assistance and claims handlers (d) Special category data | Performance of a contract with you Necessary in the substantial public interest for insurance purposes |
To register you as a new customer | (a) Identity (b) Contact (c) Information disclosed to the insurers of the policy and their assistance and claims handlers (d) Special category data | Performance of a contract with you Necessary in the substantial public interest for insurance purposes |
To receive payment from you and debt recovery purposes | (a) Identity (b) Contact (c) Payment | Necessary for our legitimate interests in receiving payment for our products and services and recovering outstanding debts owed to us |
To administer and provide your insurance and administer and handle claims. | (a) Identity (b) Contact (c) Payment (d) Transaction (e) Correspondence (f) Information disclosed to the insurers of the policy and their assistance and claims handlers (g) Special category data (h) Information we receive from other sources | Performance of a contract with you Necessary in the substantial public interest for insurance purposes |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services |
To resolve any complaints you may have | (a) Identity (b) Contact (c) Payment (d) Special category data | Performance of a contract with you Necessary for our legitimate interests to resolve customer complaints Necessary in the substantial public interest for insurance purposes |
To prevent and investigate fraud | (a) Identity (b) Contact (c) Payment (d) Special category data | Performance of a contract with you Necessary for our legitimate interests to prevent fraud Necessary in the substantial public interest to prevent fraud |
To safeguard you and others from harm | (a) Identity (b) Contact (c) Special category data | Public interest To protect vital interests |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Internet (d) Special category data | Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise Necessary to comply with a legal obligation Necessary in the substantial public interest for insurance purposes |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (f) Internet | Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Internet | Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Internet (d) Profile (e) Marketing and Communications | Necessary for our legitimate interests to develop our products/services and grow our business |
Use of Cookies (website only)
Information is automatically collected whilst navigating through and interacting with the content on our site as well as information on your device or computer (such as cookies) and this includes social media features which may collect your IP address and which page you are visiting and may set a cookie to enable the feature to function correctly. For further information on cookies and third parties that we use to host these services please read our cookie policy.
Who we share your data with
Where applicable, we share your personal information with the following types of third parties when we have a valid reason to do so:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Other third parties
Other third parties including claims handling and assistance service providers may share personal information that you have disclosed to them with us for the purposes of administering your policy. If you refuse disclosure of data to a third party which prevents the insurer from providing cover, the insurer may be released from any liability for any claim.
Alliance Health PMI Limited uses a variety of services hosted by third parties such as Google Analytics, Bing Ads, Google Tag Manager, TrustPilot. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP address.
For information on how these third parties collect and use your information, please refer to their privacy policies.
Data protection law places restrictions on transferring personal data outside of the United Kingdom (UK) and the European Economic Area (EEA). The EEA consists of the member countries of the European Union (EU), along with Iceland, Liechtenstein, Norway and Switzerland, and who are all considered to have appropriate data protection laws to safeguard your privacy and protect your rights.
We do not transfer your personal data outside the UK or the EEA.
We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will only send you marketing information regarding our own products and services if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal information with any of our trusted third parties for marketing purposes.
If you no longer wish to receive postal and/or email marketing communications from us, you can request us to stop at any time by:
If you do choose to stop receiving marketing communications from us, we will ensure that you do not receive such material going forward, unless you change your mind and specifically request it in the future.
Your data rights
Data protection law gives you rights relating to your personal information in certain circumstances. This section gives you an overview of these and how they relate to the information you give us.
The UK supervisory authority for data rights, the Information Commissioner’s Office (ICO), has also published detailed information about your rights on their website: www.ico.org.uk.
Your right to access
You have a right to request copies of the personal information we hold on you, along with meaningful information on how it is used and who we share it with.
This right always applies, but there are some instances where we may not be able to provide you with all the information we hold. If this is the case, we will confirm why we are unable to provide it - unless there is a valid legal reason that means we cannot let you know why.
Your right to rectification
If information we hold is inaccurate or incomplete, you have the right to have any inaccuracies corrected and for any incomplete data to be completed. We may need to verify the accuracy of the new information you provide to us.
If you ask us to rectify your information, we will either confirm to you that this has been done, or if there is a valid reason that this cannot be done, we will let you know why.
Your right to erasure (the right to “be forgotten”)
You have the right to request that your personal information is erased. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
If you ask us to erase your information, we will either confirm to you that this has been done, or if we are unable to delete it, let you know why and also inform you how long we will hold it for. For more information, see the “Retention Policy” section of this policy.
Your right to restrict processing
You can ask us to restrict the use of your information. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you ask us to restrict your information, we will either confirm to you that this has been done, or if we are unable to restrict it, we will inform you why.
Your right to object to direct marketing
You can object to receiving direct marketing from us.
If you do so, we will ensure that you do not receive such material going forward, unless you change your mind and specifically request it in the future. For more information, see the "Marketing" section of this policy.
Your right to object to processing
You may object to our processing of your personal data pursuant to this privacy policy where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
You have the right to request that your information be transferred to you or a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you request this, we will either act upon your instruction and confirm to you that we have done so, or if there is a valid reason that this cannot be done, we will tell you why.
You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You have the right to make a complaint at any time to the ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you have a complaint about how we use your personal information please contact us by email at feedback@kindredhealth.co.uk. Or by post:
Kindred Complaints
Alliance Health PMI Limited
54 Hagley Road
Birmingham
B16 8PE
Exercising your data rights
You can exercise any of your data rights by contacting us at hello@kindredhealth.co.uk. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will only retain data for as long is reasonably necessary for the purposes for which it is collected and in line with our data retention policy, which you can request from us by contracting us. In most cases this will be a maximum of 7 years from the expiry of an insurance contract. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We are committed to protecting the online privacy of visitors to our website. We have implemented security policies, rules and technical measures to protect your personal data from unauthorised access; improper use or disclosure; unauthorised modification; and unlawful destruction or accidental loss.
Our web site may contain links to other websites. Clinking on these links may allow third parties to collect or share data about you. We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites we provide links to from our website. Linked websites are subject to their own policies. You should read any linked website Privacy Policy before submitting any personal information to them.
If you contact us by email you should be aware that emails are not secure unless they have been encrypted. We cannot accept any responsibility for the unauthorised access to your data that is beyond our control.
@ 2023 Alliance Health Group. All Rights Reserved
Kindred Health Insurance is arranged and administered by Alliance Health PMI Limited. Alliance Health PMI Limited is an Appointed Representative of Alliance Medical Indemnity Limited who are authorised and regulated by the Financial Conduct Authority. Firm reference number is: 831527. You can check this on the Financial Services Register at https://register.fca.org.uk. Registered in England and Wales with company number: 07655729. Registered Offices: 54 Hagley Road, Birmingham, England, B16 8PE. ICO Number: ZA128182.