Privacy policy

This Privacy Policy explains how we will use your personal information when you interact with our App so please read it carefully.

SUMMARY

Below is a summary of some key terms of this Privacy Policy. We are committed to protecting your personal information when you use our Services and we want you to be confident that your personal information is safe and secure with us. This Privacy Policy explains how we use your personal information including the following: 

• where we collect your personal information from; 
• what personal information we collect; 
• how we use your personal information; 
• who your personal information is shared with; and 
• the rights and choices you have when it comes to your personal information. 

Use of our App is subject to our App’s Terms and Conditions. If you do not agree to these terms, please stop using the App immediately. 

Where we refer to “personal information” in this Privacy Policy, we mean information which constitutes “personal data” under the Law on Personal data protection of the Republic of Armenia. This can be any information that directly identifies you (such as your name or email address), but also information that identifies you indirectly or would identify you when pieced together with other information (such as your age, gender, demographic information, IP address, and cookie identifiers/other unique online identifiers). 

The main reason we process your personal information is to provide you with the App and the other services that you request from us (see section 4 below) (together, the “Services”). For certain purposes set out in section 5 below, we may share your personal information with group entities, our product partners, service providers, and regulatory or governmental bodies.  We will only hold your personal information for as long as necessary to fulfil the purposes for which we hold that personal information.   

To make an enquiry or exercise any of your rights as set out in this Privacy Policy, please contact us at: Info@insafe.am. 

1. Introduction
   1. We are Insafe financial consulting LLC. We will take your privacy very seriously. 
   2.  For the purposes of this Privacy Policy, references to “we”, “us”, “our” or “App” are to  Insafe financial consulting LLC. 
   3. Insafe financial consulting LLC (company registration number 286.110.1251881) is a  controller  in relation to the processing of the personal information that you provide to us when you use our Services. Its registered address is 4/6 / 54 Amiryan street, 0010 Yerevan, Armenia. If you have any queries relating to our use of your personal information, if you want to contact our data protection officer or if you have any other related data protection questions, please contact us at Info@insafe.am.  

2. How do we collect personal information
   1.  From you - Most of the personal information we collect will be directly from you when you use the Services.  We will collect this information from you through the App, or other similar devices, channels, or applications operated by or on behalf of Insafe financial consulting LLC.
   2.  From our product partners - If you purchase a product from one of our partners whose products or services are included on our App (“product partners”) then they may send us the information they hold relating to the product(s) you have purchased.  This allows us to track sales and improve our Services. A list of our product partners can be found in section 5. 
   3.  From our channel operators - Whilst the majority of the channels on our App are run by us, some of our channels are designed, maintained, and/or run for us by our trusted channel operators. We may receive your personal information from our channel operators and use it in accordance with section 5 below.  Where our channel operators collect your personal information on a channel that is maintained by them, they will be acting as a controller of your personal information.  A list of our channel operators can be found in section 5. 
   4.  From our suppliers - We will sometimes use other companies to collect and process your personal information on our behalf, for example, we may use IT service providers or market research agencies (see section 5 below for more detail on the categories of these suppliers). Where we use third party suppliers we will make sure that they commit to keeping your information safe. We may also obtain personal information about you from suppliers, who hold data on you themselves. 

3. What personal information do we collect?
   1. The personal information we may collect when you use the Services includes: 

• your identity information such as name and date of birth; 
• your contact information such as address, email address and telephone number; 
• Information you provide as part of your online enquiry;
• your financial information, for example, bank account or payment details or information about your credit score and/or credit report; 
• in certain scenarios, recordings of the content of your communications with us such as calls, emails and SMSs, in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training (e.g. where you email our customer services team), to prevent unauthorised use of our telecommunication systems and App, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime; 
• feedback you provide to us on your experience of using the App, which we may have requested from you in order to ensure the Services we provide you continue to meet your needs. Any feedback you provide will only be used as part of our programme of continuous improvement and will not be published on the App; and 
• information about how you come to our App and how you use it, for example, the pages viewed, the App from which you came to visit our App, changes you make to information you supply to us, details of the quotes you request and your transactions. 

2.  In order to provide you with a quote we may need to collect personal information which data protection law defines as special category data. This is personal information that is particularly sensitive.  We may also need to share this personal information with our product partners to enable them to generate a quote for you (which we are allowed to do under data protection legislation in order to arrange and/or advise on certain contract).  For details of our product partners that we share this information with, please see section 5.2.2 of this Privacy Policy. 
3.  We do not knowingly collect or store any personal information about children under the age of 16 years.
4.  If you are providing us with another person’s informationwe recommend that you first ask them to read this Privacy Policy and our Terms and Conditions, and confirm with them that they are happy for you to provide the information to us and that they understand how their details will be used. 
5.  Note that it is your responsibility to check and ensure that all information, content, material, or personal information you provide on the App is correct, complete, accurate, and not misleading and that you disclose all relevant facts. 
6. How do we use your personal information

We use your personal information for the following purposes: 

1.  For the management of our App and other Services: 

•  verifying your identity, managing, running and administering your account or use of any mobile applications if you choose to set up an App account or download mobile applications. You must be aged 16 years and over to create an account on the App, please see section 3.3 of this Privacy Policy;
•  passing it to our product partners including companies whose products or services are included on our App, with a view to them providing you with an online quote or eligibility score for the product/service requested by you. When our product partners use your personal information to provide a quote they will act as controllers of your personal information – you can see links to lists of our product partners in section 5.2.2 below; 
•  to pre-populate fields on the App when making return visits to obtain new quotes for the same product(s) or quotes across other channels on the App. This will make it easier for you to use the App by storing the personal information you provide to us (for example, your postal address and email address) and by storing personal information of any individuals associated with your accounts for example a family member or a friend. Sometimes, this involves us placing “cookies” or other tracking technologies on our App; for more information on cookies, see section 9; 
• to process a transaction between you and a third party – we will use a third party payment processing provider, Stripe, for these purposes; 
• to track sales, which may involve product partners sharing data with us relating to the product(s) you have purchased, this involves us placing “cookies” or other tracking technologies on our App; 
• to fulfil offers you are eligible for or have applied for through the App, for example if you qualify for any rewards. Where we use third parties to help us to fulfil offers, we may also need to share your personal information with them. This will also be detailed in the relevant terms and conditions for that offer; 
• by matching our data with data from other sources including to validate your information and make our Services easy to use: 
• we may validate and analyse your information and, in some cases, match it against information that has been collected by a third party to ensure that the information we hold about you is accurate, consistent and well-organised and in order to make our Services as easy to use as possible. For example, you may be required to provide your address when using the Services. In order to streamline this process, we may display address look-up services offered by third party partners. When you enter your postcode into the search bar associated with these services, we pass this information directly to the relevant third party partner, to facilitate the look up of your street address; 
•  to help gather all the information that is required to carry out the Service you have requested (particularly if some of this information may be difficult for you to locate) and to pre-populate some of the information required to carry out the Service for you by providing estimated figures 

2.  To enable us and our product partners and/or service providers to check or monitor your credit score and/or credit report, in connection with certain financial products and Services (see section 7 below for more details on who your information is shared with and what sort of processing the generation of these checks involve): 

• when you use our eligibility checker services (for example on our loans and credit cards journeys) a credit report will be generated by carrying out a ‘soft’ credit check.  We do not carry out these checks. Instead, we pass your personal information to our trusted service provider or certain of our panel of lenders who will generate these checks with their chosen credit reference agencies; 

3.  To communicate with you, including some or all of the following: 

•  sending you information about products and services which we think may be of interest to you. We will contact you (depending on your contact preferences) via email, SMS, or by other electronic means such as via social and digital media. This may include new product launches and, newsletters. When you give us your details to run a comparison you will be given an opportunity to let us know if you don’t want to receive marketing communications from us. If you are using our App and have enabled push notifications on your device, we may send you marketing messages through push notifications. If you don’t want to receive marketing communications from us, you’ll need to let us know every time you run a comparison. You can also opt out of receiving marketing communications at any time – see section 12 below. 
• This won’t affect any communications that we need to send you for the purpose of being able to provide our Services.
• sending you a confirmation email of your quote – when you obtain a quote with us, you will automatically be sent confirmation of your quote by email or SMS so that you have a record of it; 
• sending you information about the savings and credit management services. For example, if you: 
• have subscribed to our service, then we will contact you (through email, push notifications, or in-App messaging) to let you know when your  credit score from ACRA credit reporting, and/or credit report (as applicable) have been updated, how you can access our guides on credit scores and credit reports, or notifying you of significant changes to your credit score or report (see section 7 below for further information) 
•  to communicate with you at your request to offer help and support and to resolve any Service issues, including via live chat.

4. To personalise and improve aspects of our Services including: 

• to improve the personalised content and insights on our App and/or as part of our direct marketing communications. The information we collect helps us tailor our content and improve our suggestions to you and other users about products or services that may interest you or them. For example, we may undertake analysis and profiling of your credit information when you use our services in order to identify and inform you of products that we consider are likely to interest you or be suited to your credit circumstances. We also use that information to provide you with general insights about your credit health. These recommendations and insights might either be provided via direct marketing communications (as described in section 4.3 above), or through the display of information on our App; 
• to improve personalised content and insights on other Apps (for both you, and others). We make use of audience tools from digital and social media providers which enable them to match your hashed contact information that we provide them against the contact information they hold and target you on their Apps based on information about your use of our App. They might also use the same information to target advertising to other users on their webApps who they have identified as being potentially interested in the same recommendations and insights. We may also submit information about your use of the App, collected through cookies, to social media providers as part of the audience tools described above. See section 9 for more details on our use of cookies for these purposes; and 
• to help our product partners understand customer behaviours and develop and tailor their product offerings we may pass certain personal information to them (e.g. through our customer insight products that are available to subscribers). 

5.  For research, such as analysing market trends and customer demographics including: 

• we may contact you to ask you to assist us with market research by asking you questions about the Services and asking you if you would like to complete a review of the Services.  We may sometimes ask market research companies to contact you on our behalf and may use this information to improve our Apps and Services; and 
•  to use personal information relating to your quotes, your personal information, special category data in relation to your request, and information about the policies and contracts you have taken out in order to carry out various other research and analysis activities designed to help us review and improve the App or our Services, such as journey optimisation. 

6. To meet any legal obligation and/or to prevent or detect crime – for example, if a court or regulator, Governmental, compliance or law enforcement agency requires us to disclose your personal information; if it is necessary for us to disclose your personal information in connection with legal proceedings; or in order to prevent fraud and money laundering, which might involve disclosure to a fraud prevention agency. See section 5 for more detail on the parties we might disclose your personal information to for these purposes. 
7.  To enable a sale or potential sale of all or part of our business. 

5. Who is your personal information shared with
   1. When you use any of our Services, we may also share your personal information with the following third parties: 

• our channel operators (i.e., operators we partner with to help run certain aspects of our Apps and our Services) so that they may use this information in accordance with section 4 above. Where our channel operators collect your personal information on a channel that is maintained by them, they will be acting as a controller of that personal information. As mentioned in section 2.3 above, we may also receive your personal information from our channel operators and use it in accordance with this policy. You can see a list of our channel operators including a link to their Apps here. 
• our product partners whose products or services are included on our App: 
• in order to display quotes on the App we will send your personal information to our panel of product partners who provide the products you are requesting a quote for.  We need to send them your personal information so that they can generate a quote for us to display on the App.  When these companies use your personal information in this way, they will be acting as controllers of your personal information which means that they are in charge of how they handle your personal information. Please see section 6 of this policy which includes further detail about how our product partners process your personal information as controllers (including any third party sources they obtain your personal information from); 
• in order to make our eligibility checker service available to you, your personal information will be sent to our panel of product partners who provide credit card and loan services including, so that we can show you which credit cards or loans that you’re most likely to be accepted for (see also section 7 for detail on how your personal information may be shared with our service provider․
• if you choose to click through to any of our product partners to submit an application, to make it easier for you to complete your application we may pass the personal information you provide on the App to those product partners to pre-populate fields on their App to save you having to input your information again; 
• on some of our journeys you can apply and purchase our partners’ products on our App.  When you purchase a product on our App, any contract will be entered into between you and the relevant product partner and so we will pass your personal information to them; 
• if you click through to any of our product partners’ Apps, provide them with additional information on their webApps, and/or if you decide to purchase a product from any of our product partners then they will be controllers of your personal information and you should read their own privacy policy which you should find on their webApp. 
• You can see a list of our product partners in the “Who do we work with” section of our ”About us” page. 
• other third party service providers that we engage to help us provide certain services and/or functionality including: 
•  market research agencies who may contact you on our behalf in order to ask you to assist us with our research; 
• third party credit reference agencies and service providers who enable our eligibility checker services (see section 6 below for more information). 
• public sector sources where permitted or required by law or regulation, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account in order to comply with legal or regulatory requirements.

6. In more detail: Use of your personal information by our product partners
   1.  Providing a quote: In order to provide you with a quote, our product partners may exchange information about you with other companies and/or carry out checks with various databases. Our product partners act as controllers in respect of this use of personal information. This means that they determine why and how your personal information is being processed for their own purposes. Please see section 5 above for a list of our product partners and links to their privacy policies. 

We have set out below some of the common ways that product partners will share and use your information: 

• Some of our product partners will use your personal information to assess your circumstances (including information about any third party who is named on the policy) and verify the information that you have provided before providing a quote to you; 
• Some product partners may carry out checks with fraud prevention and credit reference agencies, both when you first run your quote and when we run an annual renewal quote. If product partners do these checks, they will be quotation searches only and do not show up on your credit report in the same way that a ‘hard’ check does, but will be visible to other organisations. Both public data and private data (e.g. your personal credit history) may be checked in this way;  
• Some product partners may carry out checks against data they already hold on you, (or is held by the company whose brand they administer the product for, or members of their group of companies) such as data from existing products, account data, data from previous product transactions, accounts you may hold with them or loyalty scheme data to share with insurers in order to determine your premium; 
• Our product partners may also use the personal information relating to your quotes and your personal information to create and improve the products and services they offer and to develop and improve their processes, credit risk systems, and policies, so they can better meet the needs of their customers; 

2.  Entering into a contract: If you decide to enter into a contract with one of our product partners through any of the Apps, the information you have provided to us, together with any further information requested by, and supplied by you or us to the product partner, will be held by the product partner for the purposes set out in their privacy policy and as above they will act as a controller of your personal information. Therefore, you are strongly advised to read your chosen product partner’s privacy policy and satisfy yourself as to the purposes for which the product partner will use your personal information before entering into the contract. We have no responsibility for the uses to which a product partner puts your personal information. 

7. In more detail: Credit Information Services & Credit Checks
   1.  ‘Soft’ credit checks  

• When you use some of our Services a ‘soft’ credit check may be carried out against your credit report in order to (i) assess your financial and insurance profile; (ii) verify your identity; and/or (iii) to help prevent fraud.  The credit reference agencies may keep a record of the search and you may see this recorded against your credit file but these ‘soft’ credit checks have no impact on your credit rating. ‘Soft’ credit checks are visible on your credit report but do not show up in the same way as a ‘hard’ check. These ‘soft’ credit checks are not carried out by us but by the chosen credit reference agencies of our service providers or panel members as described below;  
• The scenarios where a ‘soft’ credit check may be performed are as follows: 
• to enable our eligibility checker services (see sections below); 
• to provide you with your credit history including your credit score and credit report;
• our product partners will also carry out checks with credit reference agencies when they generate a quote for comparison both at the time you request a quote and at renewal. You should read their privacy policy for more information on how they carry out these checks 
• Where a ‘soft’ credit check is performed as part of our Services they are carried out by the following:  
• if you use our eligibility checker services then your information will be shared with  some of our credit card and loans partners. These in turn partner with the following RA credit reference agency: ACRA credit bureau from time to time.  If you use our eligibility services, a credit report will be generated by carrying out a ‘soft’ credit check.  The ‘soft’ credit checks will be used by partners to match against those partners’ own lending criteria. This information will be used to let you know your percentage chances of successfully obtaining a credit card or loan. Note that your credit report will not be provided to you directly and we will not receive it either.  
• Many of our product partners will also carry out checks with credit reference agencies when they generate a quote for comparison both at the time you request a quote and at renewal. You should read their privacy policy for more information on how they carry out these checks, which will include their selection (as controller) of their own credit reference agencies to use for these purposes. 

8. What are our legal grounds for processing your personal information?

We will only collect and use your personal information in accordance with applicable data protection laws.  Our legal grounds for processing your personal information in the ways described in this Privacy Policy are as follows: 

1.  Performance of a contract – In order to provide you with the Services and manage your account we will: (i) share your personal information with or search the Apps of our product partners to get you the quotes and/or access information required to provide you with the relevant Service from our third party partners; (ii) process any transaction between you and a third party; (iii) manage, run and administer your account; (iv) send you an automatic confirmation email of your quote when you enter your personal information to receive a quote on our App; (v) If you apply for an offer through the App, we will also use your personal information to assess your eligibility and subject to availability, fulfil the offer where the eligibility criteria has been met. When we do these activities we are processing your personal information because it is necessary to perform the contract that we have in place with you to provide you with our Services, or to take steps at your request in order to enter into a contract with you. 
2.  Consent – We will use and process your personal information where you have told us you are happy for us to process it for a specific purpose(s), for example: (i) through consenting to cookies placed for certain advertising purposes (for more information on our use of cookies, see section 9); and (ii) consenting to conduct certain “audience” based targeting services by social media platform providers (see section 10). 

You are able to withdraw your consent at any time (which will not affect the legal basis for the processing prior to your withdrawal of such consent). 

3.  Legitimate Interests – We may use and process some of your personal information where the benefits of doing it are not overridden by the interests or fundamental rights or freedoms of individuals. Our legitimate interests for processing your personal information are: 

• to monitor and communicate with you about the Services.  It is in our legitimate interest to keep you informed about your use of the Services in order to improve our Services, for example informing you of your annual renewal quotes via your account dashboard.
• to tell you about products, services and insights which we think may be of interest to you, for online advertising (see section 10), to develop marketing content and enhance our marketing strategies. We won’t send you marketing communications if you tell us not to; 
• to personalise and improve our Services, for example, we may undertake analysis and profiling on your personal information to personalise aspects of our service, including to personalise recommendations to you and others on other Apps, such as social networks; and to streamline aspects of our service such as address look-up and the pre-population of forms. We constantly aim to improve our Services to you, and using your personal information in this way helps us to do this. We do not consider that these activities would produce legal effects, or have similarly significant effects on you; 
• for market research, analysis and product improvement, including to produce the customer insight products described at section 4 which are available to subscribers. These activities help us to regularly review and improve the products and services we or our partners provide. Where possible data that we use/provide in this way will be in an anonymised or pseudonymised format; 
• to help facilitate the sale or potential sale of all or part of our business. This enables us to achieve our strategic objectives and to enable the long-term commercial success of our company. 
• You have the right to object to our use of your personal information for these legitimate interests.  If you raise an objection we will stop processing your personal information unless an exemption under RA data protection law applies, in which case we will let you know why we are continuing to process your personal information.  Please contact us at: Info@insafe.am if you wish to exercise this right, see section 13 below for further information on your personal information rights.

4.  Legal obligation – We may be required to process your personal information in order to comply with a legal obligation on us; for example, an obligation to disclose the information to a court or regulator, Governmental, compliance or law enforcement agency, or in connection with legal proceedings; or in order to prevent fraud and money laundering, which might involve disclosure to a fraud prevention agency. We may also be required to process certain personal information about you in order to respond to (and verify we are able to respond to) a data subject rights request that you have submitted. 

9. How secure is our App and what steps do we take to keep you safe?
   1. Your personal information’s security is very important to us. This is why, where it’s appropriate, our App uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure. Certain information, for example, your credit card details, is encrypted to minimise the risk of interception during transit. 
   2. You may complete a registration process when you sign up to use parts of the App. This may include the creation of a username, password, and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone. To protect your account, we ask you to choose a strong password to access your information on our App. A strong password should be lengthy and include a mixture of letters and numbers. Your password can only be reset with access to the email address registered in our system. 
10.  Your personal information rights and how to contact us
    1. You have certain rights under data protection legislation in relation to the personal information that we hold about you including: 

• Right to erasure of your information - The right to request that we delete or remove your personal information from our systems.  Data protection legislation gives exceptions to this right which, if applicable, we will explain in our response to you; 
• Right to data portability - The right to request that we move, copy or transfer your personal information to a specified third party, or to you, in a machine-readable and structured format (e.g. CSV files). There are exemptions – for example, this only applies to personal information which has been provided directly from you, which is held in digital format, and which we process with your consent or to fulfil a contract with you; 

2. To make an enquiry, or exercise any of your rights set out in this Privacy Policy please contact us by Insafe@insafe.am. 
3. This Privacy Policy shall be governed and construed in all respects in accordance with the laws of Republic of Armenia. 

11. How long do we keep your personal information?
    1. We will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted (unless a longer retention period is required or permitted by law).
    2. Generally, you can expect us to keep your personal information while you use the App or if you have an active account with us.  Where you have applied for or purchased products or services via the App we will need to keep your personal information for longer for accounting purposes – up to six (6) years following the date on which it is provided to us.
    3. If, having registered for any of our Services, you do not use them for a reasonable time (which may vary depending on the Service(s) you’ve registered for) we may contact you to ensure you’re still happy to receive communications from us.
    4. If one of our product partners processes your personal information in order to provide you with a quote they will be acting as a controller but they should only hold that personal information for so long as is reasonable in relation to providing you with that quote.
    5. If you purchase a product then the service provider will keep your personal information in accordance with their own retention periods and so you should check their own privacy policy for further information. 
    6. Even if you delete or ask us to delete your personal information it may persist on backup or archival media for legal, tax, or regulatory purposes.

12. Changes to this Privacy Policy
    1. We reserve the right to amend or modify this Privacy Policy at any time and any changes will be published on the App. The date of the most recent revision will appear on this page. If we make significant changes to this policy, we may also notify you by other means such as sending you an email.  If you do not agree with any changes please do not continue to use the App. 

Last updated January 2024