Privacy Policy

1. Introduction

APLOMB DECISIONS LTD (the "Company", "we", "us" or "our") is committed to protecting your personal data and respecting your privacy rights.

This Privacy Policy explains how we collect, use, share, and protect your personal information when you:

• Visit our website freecoverquote.net
• Submit a contact form on our landing pages
• Interact with our lead generation forms via Meta Lead Ads (Facebook/Instagram)

Please read this Privacy Policy carefully before providing any personal data.

2. Data Controller

The data controller responsible for your personal data is:

2.1 Privacy Contact

For any privacy-related inquiries, data access requests, or complaints, please contact us:

3. Legal Basis for Processing

We process personal data in accordance with the UK GDPR and the UK Data Protection Act 2018, and where applicable the EU GDPR.

Depending on the context, we rely on one or more of the following legal bases under Article 6(1):

• (a) Consent – where you explicitly consent (e.g., by submitting a form and agreeing to be contacted and/or to receive marketing, where required).
• (b) Steps taken at your request / contract – where processing is necessary to respond to your request (e.g., to handle a quote request or provide requested information).
• (c) Legal obligation – where processing is necessary to comply with legal obligations.
• (d) Legitimate interests – where processing is necessary for our legitimate interests (e.g., site security, fraud prevention, improving our services, measuring campaign performance), provided those interests are not overridden by your rights.

4. What Personal Data We Collect

When you complete a lead form (on our website or via Meta Lead Ads), we may collect the following personal data:

• Contact information: Full name, email address, phone number, postal address
• Demographic information: Date of birth, gender (if relevant to the service inquiry)
• Service-related data: Information about your insurance needs, coverage preferences, or quote requests
• Technical data: IP address, browser type, device information, referral source (collected automatically via cookies and analytics, where enabled)

5. How We Use Your Personal Data

We use your personal data for the following purposes:

5.1 Lead Generation & Commercial Communication

• To process your inquiry and connect you with our selected commercial partners (insurance providers, brokers, or service providers)
• To enable our partners to contact you directly with relevant offers, quotes, or information (where permitted)

5.2 Service Delivery

• To respond to your requests and provide customer support
• To verify your identity and prevent fraud

5.3 Legal Compliance & Audit

• To comply with legal obligations under UK and EU law (where applicable)
• To maintain records for audit, compliance, and regulatory purposes

5.4 Analytics & Website Improvement

• To analyze website traffic and user behavior (using anonymized or aggregated data where possible)
• To improve our website, services, and user experience

6. Who We Share Your Data With

We may share your personal data with the following categories of recipients:

6.1 Commercial Partners (Independent Controllers)

Your personal data may be transmitted to our selected commercial partners (e.g., insurance providers, brokers, financial service providers) for the purpose of:

• Providing you with quotes, offers, or personalized services
• Contacting you via email, phone, or SMS (where permitted)

6.2 Service Providers (Data Processors)

We may engage third-party service providers to support our operations, including:

• Web hosting and cloud storage providers
• CRM and marketing automation platforms
• Analytics and tracking tools (e.g., Google Analytics, where enabled)

These processors are bound by data processing agreements and may only process your data on our instructions.

6.3 Legal Authorities

We may disclose your personal data if required by law, court order, or regulatory authority, or to protect our legal rights, safety, or property.

7. International Data Transfers

Your personal data may be transferred to recipients located outside the UK and/or the European Economic Area (EEA), including countries that may not offer the same level of data protection.

Where such transfers occur, we ensure appropriate safeguards are in place, which may include (as applicable):

• UK International Data Transfer Agreement (IDTA) and/or the UK Addendum to the EU Standard Contractual Clauses
• EU Standard Contractual Clauses (where EU GDPR applies)
• Adequacy decisions (UK and/or EU, as applicable)

If you would like more information about cross-border transfers or copies of the safeguards we use, please contact us at privacy@freecoverquote.net.

8. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Specific retention periods:

• Lead data: Retained for up to 12 months from the date of submission for audit, compliance, and business continuity purposes
• Marketing consent records: Until you withdraw consent or request deletion (or as otherwise required to demonstrate compliance)
• Legal obligations: As required by applicable laws (e.g., tax, anti-fraud regulations)

After the retention period expires, we will securely delete or anonymize your data.

9. Your Data Protection Rights

Under the UK GDPR and UK Data Protection Act 2018 (and EU GDPR where applicable), you may have the following rights:

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our website. For detailed information, please refer to our Cookie Policy (link in footer).

Types of cookies we use:

• Strictly necessary cookies: Essential for website functionality
• Analytics cookies: To understand user behavior (anonymized where possible)
• Marketing cookies: To deliver personalized advertising (requires opt-in consent via cookie banner)

You can manage your cookie preferences through our cookie consent tool or your browser settings.

11. Security Measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction, including:

• Encryption of data in transit (SSL/TLS)
• Access controls and authentication
• Regular security audits and updates
• Staff training on data protection

However, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

12. Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these external sites. Please review their privacy policies before sharing any personal data.

13. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations.

The "Last updated" date at the top of this page indicates when the policy was last revised. Continued use of our services after changes constitutes acceptance of the updated policy.

14. Important Notice Regarding Meta Lead Ads

If you submit your details via Meta Lead Ads (Facebook/Instagram), your information is collected through Meta's platform and then provided to us for follow-up.

• APLOMB DECISIONS LTD acts as a data controller for the personal data we receive from Meta and how we use it (for example, to respond to your enquiry and/or share your data with selected partners as described in this policy).
• Meta also processes personal data for its own purposes in accordance with its own terms and privacy information. Please refer to Meta's privacy information for details of Meta's processing.

By submitting a lead form via Meta Lead Ads, you consent (where required) to APLOMB DECISIONS LTD processing your data as described in this Privacy Policy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: