We are YAVIA Solutions Limited (NI675123) (collectively referred to as “YAVIA”, “we”, “us” or “our” in this Policy).  Our registered office address is 3-5 Commercial Court, Belfast, Northern Ireland BT1 2NB

Our data protection officer is Joanne Cole (Data Protection Officer).  You can contact our Data Protection Officer by email at: joanne@yavia.co.uk

We collect, use and are responsible for certain personal information about you. When we do so, we are regulated under the data protection laws of the UK and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Our product (App) is a platform which is designed to streamline the insurance process, connecting you with your mortgage and/or insurance broker(s) and their representatives (Your Broker) and allowing you to have all of your information in one place (Service).

This Policy relates to the use of our App and Service.

We collect personal information about you when you use our App and Service.

We collect this personal information from you either directly, such as when you input information relating to you, or indirectly, such as when others input information relating to you and through your activity while on our App and/or website (see ‘Cookies’ below).

The personal information we collect about you may include:

• basic information and contact details including, but not limited to, name, date of birth, national insurance number, postal address, email address, telephone number, vehicle details, details relating to your spouse/partner and dependants and financial and employment information; and

• personal information provided to us by you or on your behalf in connection with our provision of the Service to you.  Where required, this may include special categories of more sensitive data such as health data or data relating to criminal convictions.

We use this personal information to:

• create and manage your account with us;

• verify your identity;

• provide our Service to you;

• notify you of any changes to our Service or App that may affect you; and

• improve our App and Service.

When we use your personal information, we are required to have a legal basis for doing so. There are various legal bases upon which we may rely, depending on what personal information we process and why.

The legal basis on which we process your personal data is primarily to support our legitimate interests as a business which provides the Service.

Other legal bases we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose;

• contract: where our use of your personal information is necessary for a contract we have with you;

• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations); and

• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information, which overrides our legitimate interests).

Your personal data in its non-anonymised form

As part of our Service, we will share your non-anonymised data with Your Broker.

We will share personal information with law enforcement or other authorities if required by applicable law, regulations and / or in relation to investigations by any governmental or regulatory authorities.

We will not share your personal information with any other third party unless authorised to do so by you.  More specifically, we may need to process your data or share your personal information in the following situations:

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work in relation to the Services. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the site, which will enable them to collect data about how you interact with the site, over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of shares or of company assets, financing, or acquisition of all or a portion of our business to another company.

Content

Your Broker is solely and exclusively responsible for all content released to and received by you on the App.

Third- Party Integrations

To the extent that third party integrations are deemed reasonable by us to help improve the Services in the App, you acknowledge that may use said integrations from time to time. To the extent that these integrations come with an additional cost, we shall discuss that with you and/or Your Broker at the time of integration.

Refer a friend

To the extent that we are supplied with a phone number or email address of a third person by you in relation to our ‘Refer a Friend’ initiative, that phone number will only be used in conjunction with this offer. By providing any such email address or phone number to us, you are confirming that you have obtained the consent of the relevant third person to do so and for us to contact them. Please note that in all of our communications with that person you will be stated as the person who has made the recommendation for us to make contact with them. All personal information received by us in relation to that person shall be processed in accordance with this Policy.

Connection Policy

To aid in and improve the administration of the Service to you and to any person directly connected to you (Connected Party) who is also using the App for the purpose of the Service, you or Your Broker may request from time to time that your account is connected with that Connected Party. By either sending or accepting any such invitation to do so, you acknowledge that your personal information, insurance and mortgage documentation and any related communications (to include, without limitation, any chat, videos, voice recordings) will be available and common to both you and to your Connected Party.

Transfer of your information out of the UK

We do not transfer your data outside of the UK.

Data retention and destruction

Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation).  When making decisions in relation to the retention / destruction of your personal data, we will take into account the principle of storage limitation and balance this against our requirements to retain the data, including, inter alia, for the purpose of exercising our rights contained in our terms and conditions for supply of our Service.

Our Data Protection Officer is responsible for the continuing process of identifying the data that has met its required retention period and supervising its destruction.

Cookies and similar technologies

A cookie is a small text file which is placed onto your device (e.g. smartphone or other electronic device) when you use our Service. We use cookies and other similar tracking technologies in our App. These help us recognise you and your device and store some information about your preferences or past actions.

Content

The Broker and the Broker firm is responsible for all the content going out from the platform and any content you receive.

Third- Party Integrations

All third party integrations comes with an extra cost discussed by YAVIA at the time of integration. This is not included in the part of their current subscription or the one-off fee.

Refer a friend

The supplied Phone number will only be used in conjunction with this ‘Refer a Friend’ offer. By entering your friends’ email phone number you are confirming that you have obtained their consent for this. Please note, you will be stated as the person who has made the recommendation in the  message to your friend. YAVIA will process their data in accordance with their privacy policy. When you refer a friend, you give the Broker the right to contact the referral.

Transfer of your information out of the UK

We do not transfer your data outside of the UK.

Data retention and destruction

Data protection laws require us to retain personal data for no longer than is necessary for the purposes for which it is processed (principle of storage limitation). When making decisions in relation to the retention / destruction of your personal data, we will take into account the principle of storage limitation and balance this against our requirements to retain the data, including, inter alia, for the purpose of exercising our rights contained in our terms and conditions for supply of our Service. Our Data Protection Officer is responsible for the continuing process of identifying the data that has met its required retention period and supervising its destruction.

Cookies and similar technologies

A cookie is a small text file which is placed onto your device (e.g. smartphone or other electronic device) when you use our Service. We use cookies and other similar tracking technologies in our App. These help us recognise you and your device and store some information about your preferences or past actions.

You have the right, in accordance with data protection law, to:

• access and information – you have the right to request details and a copy of the personal data that we hold about you and information as to how we process it;

• rectification – you have the right to request that any inaccurate or incomplete data that we hold about you is corrected or updated;

• erasure – you have the right to request that we delete the personal data that we hold about you. This is also known as ‘the right to be forgotten’.  Please note that this is not an absolute right.  This means that it only applies in certain circumstances.  We will notify you if we are unable to comply with your request;

• restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for a particular purpose or to object to such processing;

• data portability – you have the right to request that we provide you with a copy of your personal data in a form which ensures that it is easily transferable from one IT environment to another in a safe and secure manner; and

• withdraw consent – if we are processing your personal data on the basis of your consent, you may withdraw that consent at any time.

If you would like to exercise any of those rights, please:

• email our Data Protection Officer;

• let us have enough information to identify you;

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

• let us know the information to which your request relates.

You have the right to submit a complaint to the supervisory authority for data protection in the United Kingdom, if you feel that we are not processing your personal data in accordance with the law.  The relevant body is the Information Commissioner’s Office (ICO).  Its contact details are:

The Information Commissioner’s Office – Northern Ireland 3rd Floor 14 Cromac Place, Belfast BT7 2JB

Telephone: 028 9027 8757 Email:

ni@ico.org.uk

We would, however, be grateful for the opportunity to address your concerns before an approach is made to the ICO.  Please therefore contact our Data Protection Officer in the first instance.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.