Privacy Policy

AboAbout Us

This notice explains how One Sure Insurance Ltd and Freedom Retail Ltd collects, uses and protects your personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. One Sure Insurance Ltd and Freedom Retail Ltd are One Sure Group companies providing a range of insurance and financial services. It applies to all trading names under One Sure Insurance Ltd and Freedom Retail Ltd. Trading names associated with One Sure Insurance Ltd include, but are not limited to; Staveley Head, Compare HGV Insurance, Unicom Insurance Services, MoverCover, Tradewise Insurance Services, Spitfire Insurance and i4MT. Freedom Retail Ltd trades as Freedom Brokers.

One Sure Insurance Ltd is an independent insurance broker, authorised and regulated by the Financial Conduct Authority (FCA), company number 05649077, FCA reference number 447730 and is registered with the Information Commissioner’s Office (ICO) under number Z9366683.

Freedom Retail Ltd is an Appointed Representative of One Sure Insurance Ltd. Their company number is 16372250. Freedom Retail Ltd is not directly authorised by the Financial Conduct Authority (FCA) but operate under the regulatory umbrella of it’s principal firm One Sure Insurance Ltd. They are registered with the Information Commissioner’s Office (ICO) under number ZB901201.

The registered address for both One Sure Insurance Ltd and Freedom Retail Ltd is Spitfire House, 142-154 Congleton Road, Talke, Stoke on Trent, Staffordshire, England, ST7 1LX.

What is personal data?

Personal data refers to any information relating to an individual who can be identified directly or indirectly. This includes details such as your name, address, date of birth, email address, telephone number, IP address, and policy or account numbers. It can also include more sensitive types of data, known as special category data, such as health information or criminal conviction data, which we may process when necessary to provide certain insurance products or services.

What Information do we collect and where do we get it from?

For us to arrange and administer insurance for you we will collect and process the following personal data, depending on your relationship with us:

• Name, address, date of birth, contact details
• Employment, driving, and licensing history
• Details relating to vehicles, property, or business
• Payment and financial information
• IP address, browser and device data
• Communications and call recordings
• Claims history and incident details
• Special category data (e.g. criminal convictions, health) where relevant to insurance

Where you disclose the personal data of others, you must ensure that you are entitled to do so.

If you object to the collection, sharing and use of your personal data, we may be unable to provide you with our products and services.

Where you use our online portals, we collect information such as user login credentials, activity logs and any communications through the portal.

Where telematics devices are installed in your vehicle, or where you use a telematics-enabled mobile app, the following types of data may be collected:

Vehicle Location Data

• Real-time GPS location
• Journey start and end points
• Routes taken

Driving Behaviour

• Speed
• Acceleration and braking patterns
• Cornering and turning
• Instances of harsh driving

Usage Data

• Time and duration of journeys
• Frequency of vehicle use
• Mileage

Vehicle Diagnostics (depending on the device)

• Engine status
• Battery voltage
• Maintenance alerts

Crash Detection

• Sudden impact or collision detection
• Incident location and time

This data is used to assess driving behaviour, calculate risk more accurately, detect fraud, and may influence your insurance premium or eligibility for certain products.

We usually collect your personal data directly from you or someone acting on your behalf, such as through online forms, phone calls, written correspondence, or paper-based documents we complete with you. We may also verify your identity using third-party sources like credit reference agencies.

In some circumstances, we may also receive your personal data from third-party premium finance providers. For example, where you previously arranged finance with another provider, we may receive details such as your direct debit mandate so that this can be updated and transferred to our new finance provider, Premium Credit Limited (PCL). This ensures continuity of your premium finance arrangements.

In these situations, we act as the data controller, determining how and why your information is processed. Where we engage third parties to handle your data strictly under our instruction, they act as data processors.

Where other parties, such as insurers or administrators, are involved in underwriting or managing your policy, we may act as joint data controllers, sharing responsibility for how your personal data is used.

Why do we need your personal data and how do we use it?

We collect and use your personal data to provide you with insurance and financial services and to fulfil our contractual and legal obligations. The legal bases on which we rely to process your data typically include the performance of a contract, compliance with legal obligations, our legitimate business interests, and, where applicable, your explicit consent.

We may use your personal data for the following purposes:

• To provide insurance quotations, arrange insurance contracts, and administer your policy throughout its lifecycle, including processing mid-term adjustments, renewals, and claims.
• To verify your identity and carry out credit checks where required.
• To arrange premium finance where applicable and manage financial transactions associated with your insurance.
• To comply with legal and regulatory obligations, such as those imposed by the Financial Conduct Authority (FCA), HMRC, or the Information Commissioner’s Office (ICO).
• To investigate and prevent fraud, financial crime, or other illegal activities, including data sharing with appropriate authorities and third-party databases for fraud prevention purposes.
• To assess risk and pricing using automated decision-making tools, which may include profiling based on the information you provide. Where applicable, you have the right to request human review of such decisions.
• To record and monitor communications (including telephone calls, emails, and webchat) for training, quality assurance, and regulatory compliance.
• To develop and improve our products, services, and customer experience, including through statistical analysis and market research.
• To manage your account and respond to your queries or complaints effectively.
• To market similar products or services to you where we have a legitimate interest, unless you have opted out. Where consent is required for marketing or data sharing, this will be clearly requested and can be withdrawn at any time.

In addition, we may process special category data (such as health details or criminal convictions) where necessary for the purpose of arranging or administering your insurance policy. This is done under the legal condition of substantial public interest, as permitted by data protection legislation.

If your insurance includes telematics (such as a smartphone app or in-vehicle device), we may collect data such as location, speed, braking, and journey patterns. This data is used to assess driving behaviour, provide trip information, aid in accident support, and inform premium pricing.

In providing your personal data to us, you are forming a contract with One Sure Insurance Ltd or Freedom Retail Ltd. If you contact us for a quote or make an enquiry, we may also rely on legitimate interest to follow up with relevant information.

Where your data is shared with insurers, finance providers, service partners, or other organisations involved in administering your insurance, these parties may act as either processors or joint controllers of your data. We ensure that appropriate legal and technical safeguards are in place to protect your information at all times.

How is your information shared?

In order to deliver our services, administer your insurance policy, and comply with legal and regulatory obligations, we may need to share your personal data with third parties. We will only share the information necessary for the relevant purpose and always ensure that appropriate safeguards are in place to protect your data.

We may share your personal information with:

• Insurers, underwriters, intermediaries, and premium finance providers involved in quoting for, arranging, underwriting, or administering your insurance policy.
• Claims handling services, loss adjusters, accident management companies, and uninsured loss recovery agents where applicable.
• Third-party service providers we engage to perform services on our behalf, such as IT system providers, customer contact centres, document production services, compliance support, and payment processors.
• Credit reference agencies, identity verification providers and anti-fraud databases, including those used industry-wide to prevent and detect crime and fraud.
• Group companies within One Sure Group, where this may help to provide you with alternative cover options, renewals, or additional services.
• Regulators, statutory bodies, or law enforcement agencies where required to meet our legal obligations or in response to valid legal requests.
• Debt recovery agencies or solicitors acting on our behalf to recover outstanding payments.
• Service partners that provide ancillary benefits or support related to your insurance (such as MOT reminders or breakdown services) where relevant and necessary.
• Parties involved in a potential business restructure, merger, or sale of part or all of our business, where your policy would need to be maintained or transferred.

In the case of telematics or app-based insurance products, your data may be shared with third-party telematics providers for the purposes of device installation, monitoring, and driving behaviour analysis.

If you choose to finance your insurance premium by instalments, we may share your personal data with Premium Credit Limited (PCL), who act as an independent data controller. PCL will use your information to carry out credit, affordability, identity verification, and anti-money laundering checks (which may involve third-party agencies), prepare relevant credit agreements, and manage your direct debit payments.

where your policy is set to auto-renew, we will notify you in advance. Unless you object, your information will be transferred to PCL so that your premium finance can continue seamlessly. You have the right to object to this transfer; however, if you do so, we will not be able to arrange premium finance for your policy. This means you will need to pay your premium in full or make alternative arrangements directly with another finance provider.

Once your data is transferred to PCL, they will provide you with a copy of their own privacy notice, setting out how they process your information as a separate controller.

Where data is shared with third parties outside of the UK or European Economic Area (EEA), we ensure that appropriate safeguards (such as standard contractual clauses or adequacy decisions) are in place to protect your data and uphold your rights under UK data protection law.

International Data Transfers

In certain circumstances, the personal data we collect from you may be transferred to and processed in countries outside of the United Kingdom. This may occur where we or our third-party service providers operate internationally, including when using cloud-based platforms or telematics providers. Where such transfers take place, we ensure that your personal data is protected by appropriate safeguards. These may include the use of standard contractual clauses approved by the UK Information Commissioner’s Office (ICO), International Data Transfer Agreements (IDTAs), or ensuring that the country has an adequacy decision from the UK Government. We also conduct transfer risk assessments where required and ensure that any recipient of the data adheres to strict data protection standards and security measures. You can request more information about international data transfers and the safeguards we use by contacting our Data Privacy Representative. (Refer to the ‘How to Contact Us’ section at the end of this document).

How long do we keep your personal data?

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, and contractual obligations, or for legitimate business interests such as statistical analysis, product development, and marketing.

If no insurance contract is entered into, we will typically retain your data for up to 3 years. Where a policy is in place, data may be retained for up to 40 years after you cease to be a customer of One Sure Insurance Ltd or Freedom Retail Ltd, particularly where required for claims handling or regulatory purposes.

In some cases, we may need to retain your data for longer—for example, if it is relevant to a legal claim, required by law, or where there is a reasonable expectation of a future claim arising.

How do we protect your data?

We are committed to ensuring that your personal information is secure. We use a range of technical and organisational measures to protect your data from unauthorised access, unlawful processing, accidental loss, destruction or damage.

These measures include robust access controls, encryption, firewalls, regular system monitoring, secure storage facilities, staff training, and procedural safeguards to ensure data is handled in line with our internal policies and regulatory expectations.

Where we work with third-party service providers who process your data on our behalf, we ensure that appropriate contractual and security arrangements are in place. These third parties are only permitted to process your data under our strict instructions and not for their own purposes.

Any data transferred outside of the UK or the European Economic Area (EEA) will only be done where adequate levels of protection are in place, as required by applicable data protection laws. We will take all reasonable steps to ensure your data remains secure and protected wherever it is processed.

All employees and contractors are required to maintain the confidentiality of personal data, and we regularly review our data handling practices and security measures to ensure they remain effective.

If you suspect any misuse or unauthorised access to your data, please contact our Data Protection Representative immediately at datarequests@onesureinsurance.co.uk.

What are your rights?

You have a number of legal rights concerning the personal information we hold about you. These rights allow you to understand and control how your data is used. You can exercise any of the rights listed below by contacting our Data Protection Representative at datarequests@onesureinsurance.co.uk.

Your rights include:

• Right of Access – You have the right to request a copy of the personal data we hold about you.
• Right to Rectification – If your information is incorrect or incomplete, you can request that it be updated or corrected.
• Right to Erasure – In certain circumstances, you may request that we delete your personal data, for example, where the data is no longer needed or you withdraw your consent.
• Right to Restriction of Processing – You have the right to request that we stop or limit processing your data in certain circumstances.
• Right to Data Portability – Where processing is based on your consent or a contract and is carried out by automated means, you may request to receive your personal data in a structured, commonly used and machine-readable format and have it transferred to another controller.
• Right to Object – You may object to processing based on our legitimate interests or for direct marketing purposes.
• Rights in relation to automated decision-making and profiling – You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you. You can request human intervention and challenge such decisions.

Where we rely on your consent to process your data (for example, for marketing purposes), you can withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Please note that some rights may be limited where we are required to retain data to comply with legal or regulatory obligations or where we are entitled to retain data under applicable law.

We will not charge a fee to process these requests, however, if your request is considered to be repetitive, manifestly unfounded and/or excessive, we are entitled to refuse to comply with the request or charge a reasonable administration fee. A response to your request will be provided to you within 30 days of us receiving a valid request. We do have the authority to extend these requests by up to 3 months; following ICO guidance. If we do need to do this, we will write to you to confirm this within 30 days of receiving your original request to explain our reasons why.

If you are dissatisfied with how we handle your personal data or your rights, you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.

Complaints

You can raise a complaint or concern by contacting our Data Protection Representative:

Email: datarequests@onesureinsurance.co.uk
Post: Data Protection Representative, One Sure Insurance Ltd, Spitfire House, 142-154 Congleton Road, Talke, Stoke-on-Trent, Staffordshire, ST7 1LX

We will acknowledge your complaint promptly and aim to resolve it as efficiently as possible in line with our complaints handling procedures.

If you are dissatisfied with our response, or believe we are not processing your personal data in accordance with the law, you have the right to lodge a complaint with the UK’s independent authority for data protection:

Information Commissioner’s Office (ICO)
Website: www.ico.org.uk
Helpline: 0303 123 1113

How to Contact Us

If you have any questions about this privacy notice, the information we hold about you, or how we use your data, please get in touch with us using the contact details below.

Data Protection Representative
One Sure Insurance Ltd
Spitfire House
142-154 Congleton Road
Talke
Stoke-on-Trent
Staffordshire
ST7 1LX

Email: datarequests@onesureinsurance.co.uk
Phone: 01782 880140
Website: www.onesureinsurance.co.uk

Use of cookies

A cookie identifies your computer to a server that then enables information to be stored on the hard drive of your computer. Cookies allow a computer to be identified as corresponding to one that has accessed another website or visited a site previously. Cookies are commonly used on the Internet and do not harm your computer system. We may, from time to time, use and serve cookies, pixel tags or action tags. Any information that is collected via cookies, pixels and action tags is completely anonymous.

We use cookies, pixel tags or action tags for various purposes, including:

• Collating anonymous aggregated information that is used to manage and plan enhancements to our services.
• Evaluating the effectiveness of our advertising and promotions on third party websites, for example by tracking whether these advertisements are clicked on by users.

We are continually looking to adopt and implement certain practices and technologies in order that we may improve your user experience.

Move Cover works with third parties to research certain usage and activities on our website on our behalf. No personal information about you is shared, however in the course of conducting this research these third parties may place a unique ‘cookie’ on your browser.

In order to develop our website in line with customer needs Move Cover is working with various tracking software providers to track usage on our website. These tools provide us with statistics to show us which pages on our website are visited most frequently and how long visitors spend on our website. We use this information to help us plan how we should improve the website.

The tracking tools use a cookie to track the number of unique users of the site. It tells us whether we have a small number of regular visitors to the website or a large number of infrequent visitors. None of the information can be traced to an individual – we do not know who you are as a unique user, merely that there are a certain number of people using the website. The cookie only relates to what goes on in the Move Cover website and quote engine and the information cannot be used for marketing on an individual basis. For more information about how the tracking tools collect data, please contact us.

The cookies we use on our website.

Cookie Provider	Cookie Name	Purpose
Cloudflare	_cfduid	Used by the content network, Cloudflare, to identify trusted web traffic.
Google Tag Manager	_dc_gta_UA-#	To control the loading of a Google Analytics script tag.
Google Tag Manager	_ga	Registers a unique ID that is used to generate statistical data on how visitors use the website.
Google Analytics	_gat	Used by Google Analytics to throttle the request rate.
Google Analytics	_gid	Registers a unique ID that is used to generate statistical data on how visitors use the website.
Twitter	_twitter_sess	Collects anonymous data related to the user’s visits to the website. This includes the number of visits, average time spent on the website and which pages have been loaded, with the purpose of personalising and improving the Twitter service.
Google Ads	ads/conversion/#	To re-engage visitors that are likely to convert to customers based on thevisitor’s online behaviour across websites.
Google Ads	ads/ga-audiences	To re-engage visitors that are likely to convert to customers based on thevisitor’s online behaviour across websites.
Google Ads	ads/user-lists/#	To re-engage visitors that are likely to convert to customers based on thevisitor’s online behaviour across websites.
Youtube	CheckConnectionTempCookie#	Used to check if the user’s browser supports cookies.
Google Analytics	collect	To send data to Google Analytics about the visitor’s device and behaviour. This tracks the visitor across devices and marketing channels.
Twitter	ct0	Twitter social tracking cookie.
Facebook	fr	To deliver a series of advertisement products such as real-time bidding from third party advertisers.
Google	GAPS	To identify the user when sharing content with a Google +1 button.
Twitter	guest_id	Collects anonymous data related to the user’s visits to the website, such as the number of visits, average time spent on the website and which pages have been loaded, with the purpose of personalising and improving the Twitter service.
Doubleclick	IDE	To register and report the website user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.
Google Ads	NID	To register and report the website user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.
Joomla	personalization_id	Joomla user tracking cookie.
Google Tag Manager	test_cookie	To check if the user’s browser supports cookies.
Facebook	tr	Facebook conversion tracking.
Joomla	UUID#[abcdef0123456789]{32}	Joomla unique identifier cookie.

How can I stop cookies, and what effect will this have?

You can stop cookies from being deployed on your computer by configuring your browser not to accept them or opt-out. Please refer to your browser’s ‘help’ facility.

If cookies are already on your system, you can delete them – For more information on cookies and deletion of cookies please visit: http://www.allaboutcookies.org/manage-cookies

Please be aware that deleting certain cookies can result in difficulties when navigating around sites.

Third-party websites

We are not responsible for the privacy policies and practices of other websites. Whenever possible we will only partner with other websites which maintain the same standards as are present on our own website but we cannot guarantee this and you are advised to check the privacy policy on each website that you visit.

Law

This Privacy Policy is subject to English Law and to the exclusive jurisdiction of the English Courts.