Privacy Policy

This is the privacy notice for Cignpost Group Limited. Cignpost Group Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data if the following circumstances:

When you visit our website.
It will also explain how we look after your data when you provide it to us direct, or indirect.

This policy is set out as follows:

Important Information and who we are
The Data we collect about you
How is your personal data collected
How we use your personal data
Disclosures of your personal data
International Transfers
Data Security
Data Retention
Your Legal Rights
Financial Conduct Authority (FCA)
Glossary

1 Important Information and who we are

Who We Are

Cignpost Group Limited (Collectively referred to as “Cignpost”, “we”, “us” or “our” in the privacy notice) is a company which is incorporated in England & Wales with the number 9071774. Cignpost Group consists of:

Cignpost Advised Limited (CRN 4296341)
Cignpost Limited (CRN 6876406)
Cignpost Services Limited (CRN 8957224)
Cignpost Financial Services Limited (CRN 8427716)
Cignpost Corporate Limited (CRN 9246549)
Cignpost Direct Limited (CRN 15785909)
Cignpost Group Limited (CRN 9071774)

We provide you with intermediary services in relation to protection insurance products. Where you have provided your personal information to us directly, we will be the Data Controller. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights under the Data Protection Act please contact the DPO using the details set below.

Contact Details

By post: The Data Protection Officer, Cignpost Group Limited , The Stables, Peper Harow, Godalming, GU8 6BQ Email address: dataprotection@cignpost.com You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This privacy notice was last updated on the 16th January 2025 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data such as first name, maiden name, last name, employment status, marital status, title, date of birth and gender.
Contact Data such as address, email address and telephone numbers.
Employment Status such as current job and employment history
Financial Data such bank account and salary.
Lifestyle Information such as hobbies and activities.
Health Information such as medical history
Family Details such as dependents and beneficiaries
Product Details such as plan numbers and premium amounts.
Evidence of Consent were used

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

SPECIAL CATEGORY AND CRIMINAL DATA

Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data, biometric data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection. We may process:

health information and lifestyle information when providing intermediary services in relation to a protection insurance product; and/or
criminal conviction or offence information when providing intermediary services in relation to a general insurance product

In addition to the lawful basis for processing this information set out in the table below, we will be processing it either

for the purpose of advising on, arranging or administering an insurance contract or
for the establishment, exercise or defence of legal claims.

IF YOU FAIL TO PROVIDE PERSONAL DATA

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 (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us. The personal data we obtain from other sources may include the following:

Direct interactions. Were we contact you or you contact us to
- apply for quotes, products or services that we supply as an intermediary.
- request marketing to be sent to you.
- give us some feedback.
- Call recordings.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
  1. analytics & tracking providers some such as Google based outside the EU;
  - Google Tag Manager
  - Google Analytics
  - WordPress
  - YouTube
  - Inchora Session
  - Hotjar
  - Cubed.ai
  1. advertising networks based inside & outside the Uk and the EEA;
  - Google Adwords
  - Bing Ads
  - Google Display Network
  - PPC Protect
  - Facebook ads
  - Instagram
  - Twitter
  - Linkedin
- From leads generators e.g. If you complete an online quote form.
- Other lenders and/or product providers eg product details
- From Financial Conduct Authority (FCA) and Financial Ombudsman Service (FOS) eg details of any complaint about our services and/or the suitability of any advice we give you
- From identification and verification checking agencies eg identity information and sanction check information

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

We only rely on consent as a legal basis for processing your personal data in relation to marketing communications to you via phone, email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

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 register you as a new customer	Identity Contact	Performance of contract with you
Call recordings for Proof of contract Record of conversation Assessing quality of sale Training Purposes Prevention & detection of crime	All type of data mentioned in this chart	Necessary for our legitimate interest to monitor sales quality and provide evidence in disputes over sales Proof of contract Necessary to comply with a legal obligation. Contract is verbal Performance of contract with providers
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identify Contact Profile 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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporing and hosting of data)	Identify Contact Technical	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
CCTV recordings	Images	Necessary for our legitimate interests (to protect our staff and premises from unwanted persons)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identify Contact Profile Usage Marketing and Communications Technical	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 relationship and experiences	Technical Usage	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 To provide you with intermediary services and to assist in the administration of any products you have obtained through us	Identify Contact Technical Usage Profile Identify Contact	Necessary for our legitimate interests (to develop our products/services and grow our business) Performance of a contract
To engage with you To obtain and record the information required to provide you with intermediary services to apply for decisions in principle for mortgage products and/or quotations for protection and/or general insurance products on your behalf to apply for products on your behalf	Identify Contact Financial Transaction Communications Medical Criminal	Performance of a contract Necessary for our legitimate interests to provide quotes and make sales
To manage compaints	Identify Contact Communications	Compliance with a legal obligation
To manage legal claims	Identify Contact Communications	Legitimate interests – we have a legitimate interest in protecting ourselves from breaches of legal obligations owed to us and to defend ourselves from litigation.
To retain records of any services or advice provided to you in accordance with our regulatory obligations. in order to defend potential legal claims or complaints	Identify Contact Financial Transaction Communications Medical Criminal	Compliance with a legal obligation Legitimate interests – we have a legitimate interest in protecting ourselves from breaches of legal obligations owed to us and to defend ourselves from litigation.
To maintain our regulatory duties to detect, prevent and investigate fraudulent applications for products to undertake investigations into allegations of misconduct and/or criminal offences to notify the relevant authorities of any suspicious activity following an investigation undertaken by us into allegations of misconduct and/or criminal offences	Identify Contact Financial Transaction Communications Medical Criminal	Compliance with a legal obligation
To undertake anti-money laundering, identification verification checks, including assessment of your sanction check information	Identify Contact Financial Transaction Communications Medical Criminal	Compliance with a legal obligation
To evidence satisfaction of any request made by you in accordance with your rights under data protection regulation	Identify Contact Communications	Compliance with a legal obligation

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data 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). You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Inchora group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. By email: customerservice@cignpost.com By Post: Cignpost Group Limited, The Stables, Peper Harow Park, Godalming, Surrey, GU8 6BQ Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie policy

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

6. INTERNATIONAL TRANSFERS

Some of our external third parties who we use in our processes may process your information outside the UK and/or the EEA, to ensure your data is protected to an adequate level we will ensure that appropriate safeguards and security measures are in place for that transfer and storage as required by applicable law and we will have implemented at least one of the following:

We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government. For further details, see https://www.gov.uk/government/publications/uk-approach-to-international-data-transfers/international-data-transfers-building-trust-delivering-growth-and-firing-up-innovation#uk-adequacy.
Where we need to transfer your personal data to countries that do not have an adequacy agreement, we will ensure a Transfer Risk Assessment is completed and use an International Data Transfer Agreement. For further details, see https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/
If you use our services whilst you are outside the EEA and/or the UK, your information may be transferred outside the EEA and/or the UK in order to provide you with those services.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

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 may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

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.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may 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.

10. FINANCIAL CONDUCT AUTHORITY (FCA)

Who regulates us?

Cignpost Advised Limited is authorised and regulated by the Financial Conduct Authority. Financial Services Register number for Cignpost Advised Limited is 304130. Registered address is The Stables, Peper Harow, Godalming, GU8 6BQ.

Who is The Financial Conduct Authority (FCA)

The FCA is the independent watchdog that regulates financial services. It requires us to give you this information. You should use this information to decide if our services are right for you. Complaints procedure If you wish to register a complaint regarding Insurance products, please contact us:

By email: please send us your complaints to: compliance@cignpost.com
By post: Complaints Department, The Stables, Peper Harow, Godalming, GU8 6BQ.

We will then investigate your complaint and get back to you. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service. Please see link for further details: http://financial-ombudsman.org.uk

11. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Hatbox Group acting as controllers or processors and who are based in the UK and provide IT and system administration services, Accounting Services, Compliance, Marketing and Communication Services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

Service providers acting as processors based in the United Kingdom who provide:
- IT and system administration services.
- Product providers
- Feedback and service references
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data 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. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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. 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.