We (also referred to as “we”, “us”, or “our”), Up Digital Risk Limited, are an appointed representative (FRN 1036105) of Independent Broking Solutions Limited who are authorised and regulated by the Financial Conduct Authority. Its Financial Services registration number is 312026. Independent Broking Solutions Limited (IBS) are a registered company in England and Wales (company number 00616849).

Our registered address is 4th Floor, 1 George Yard, City of London, London, England EC3V 9DF.

The term ‘you’ or “your” refers to the user or viewer of our website.

The purpose of this notice

This Notice is designed to help you understand what kind of information we collect in connection with our products and services and how we will process and use this information. In the course of providing you with products and services we will collect and process information that is commonly known as personal data.

This Notice describes how we collect, use, share, retain and safeguard personal data.

This Notice sets out your individual rights; we explain these later in the Notice but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.

What is personal data?

Personal data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, their gender and contact details.

Personal data may contain information which is known as special categories of personal data. This may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to or sexual orientation.

Personal data may also contain data relating to criminal convictions and offences.

For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.

Personal data we collect

In order for us to arrange and administer insurance for you, we will collect and process personal data about you. We will also collect your personal data where you request information about our services, customer events, promotions and campaigns.

We may also need to collect personal data relating to others in order to arrange and administer insurance. In most circumstances, you will provide us with this information. Where you disclose the personal data of others, you must ensure you are entitled to do so.

You may provide us with personal data when completing online quote or contact forms, when you contact us via the telephone, when writing to us directly or where we provide you with paper based forms for completion or we complete a form in conjunction with you.

We will share your personal data within our firm, group of companies, business and with business partners. This is normal practice within the insurance industry where it is necessary to share information in order to place, quantify and underwrite risks, to assess overall risk exposure and to process claims. It is also necessary to determine the premium payable and to administer our business.

We also share personal data with authorised third parties, this is necessary where we are required to do so by law, where we need to administer our business, to quote for, source, place and administer your insurances to perform underwriting activities and to process claims. Some examples follow:

• Insurers;
• Underwriters;
• Premium finance providers;
• Credit reference agencies;
• Debt recovery agencies;
• Claims handling companies;
• Loss adjusters;
• Insurance brokers;
• Reinsurers;
• Regulators.

We may record your communications with us when contacting our customer care, complaints and other customer focused functions.

Where we collect data directly from you, we are considered to be the controller of that data i.e. we are the data controller. Where we use third parties to process your data, these parties are known as processors of your personal data. Where there are other parties involved in underwriting or administering your insurance they may also process your data in which circumstance we will be a joint data controller of your personal data.

A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data.

A data ‘processor’ means the individual or organisation which processes personal data on behalf of the controller.

As a provider of insurance services, we will process the following categories of data:

• Personal data such as an individual’s name, address, date of birth, gender, contact details and details of historic claims
• Special categories of personal data such as health and details on historic claims resulting in injury (physical and physiological)
• Data relating to criminal convictions and offences such as details of driving offences or insurance fraud

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.

For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place.

If you require more information about our insurance processes or further details on how we collect personal data and with whom we share data with, please contact our data privacy representative by e-mailing jonathan.sprules@ibsbroking.com.

Why do we need your personal data?

We will use your personal data for the performance of our contract with you, to quote for and provide you with insurance products and services, to process claims and renewals, to administer your policy and our business, to respond to any requests from you about services we provide and to process complaints. We will also use your personal data to manage your account, perform statistical analysis on the data we collect, for financial planning and business forecasting purposes.

In purchasing our products and services you should understand that you are forming a contract with us. If you contact us for a quote or request details on the services we provide, we consider ourselves as having a legitimate business interest to provide you with further information about our services.

We will retain your personal data at the end of any contractual agreement for a period of six years. Where you have submitted a claim, we will retain your data for a period of six years, if it is a non-injury claim; where an individual has been injured (physical and physiological), we will retain your data for six years. Where you have requested a quote, we will retain your personal data for six years, where you have contacted us for details of our services and products, we will retain your personal data for six years. Where you make a complaint we will retain the data for six years. Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.

The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis (profiling) and product development and marketing purposes.

Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.

Please contact our data privacy representative if you object to the use of, or you have any questions relating to the use of, your data, the retention of your personal data, automated decision making services/tools and techniques.

Your rights

Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.

These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:

• The right to be informed about the personal data being processed;
• The right of access to your personal data;
• The right to object to the processing of your personal data;
• The right to restrict the processing of your personal data;
• The right to rectification of your personal data;
• The right to erasure of your personal data;
• The right to data portability (to receive an electronic copy of your personal data);
• Rights relating to automated decision making including profiling.

Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.

In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.

You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health related matters.

The flow of data within the insurance sector is complex and we ask you to keep this in mind when exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations to help satisfy your request this may impact on timescales.

If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact our data protection officer by emailing jonathan.sprules@ibsbroking.com to 1 George Yard (4th Floor), London, EC3V 9DF.

Protecting your data

We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our firm, group of companies, business, and authorised third parties.

Data protection officer

To comply with our legal obligations and to ensure data privacy and protection has appropriate focus within our organisation we have a Data Protection Officer who reports to our senior management team. The Data Protection Officer’s contact details are as follows:

Jonathan Sprules
1 George Yard (4th Floor), London, EC3V 9DF

Complaints

If you are dissatisfied with any aspect of the way in which we process your personal data please contact data protection officer/data privacy representative. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office (ICO). The ICO may be contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.

How to contact us

If you have any questions regarding this Notice, the use of your data or your Individual Rights please contact our Data Protection Officer. Contact details are as follows:

Jonathan Sprules
1 George Yard (4th Floor), London, EC3V 9DF
0207 347 5670
Jonathan.Sprules@ibsbroking.com

Welcome to Up Digital. These Terms and Conditions govern your use of our website, services, and any related platforms. By accessing or using our Services, you agree to these Terms. If you do not agree, please do not use our Services.

You agree to use our Services only for lawful purposes and in compliance with all applicable laws and regulations.

You must not misuse the website, attempt to gain unauthorised access, or engage in activity that could damage, disable, or impair our Services.

Information provided to us must be accurate, complete, and current.

All insurance products are subject to underwriting criteria and eligibility requirements.

Any quotes provided through our platform are non-binding until accepted by both you and the insurer.

Policy terms, coverage, exclusions, and conditions will be outlined in the individual policy documentation.

All content, trademarks, and materials on our Services are owned by or licensed to Up Digital.

You may not copy, distribute, modify, or use any materials without our prior written consent.

Our Services may contain links to third-party websites or resources. We are not responsible for their content, policies, or practices.

We provide the Services “as is” and make no guarantees that they will be error-free or uninterrupted.

To the fullest extent permitted by law, Up Digital is not liable for any direct, indirect, incidental, or consequential damages arising from your use of our Services.

You agree to indemnify and hold harmless Up Digital, its directors, employees, and affiliates from any claims, liabilities, damages, or expenses arising out of your use of our Services or breach of these Terms.

Your use of our Services is also governed by our Privacy Policy. By using our Services, you consent to the collection and use of your data as described in the Privacy Policy.

We may update these Terms from time to time. Changes will be posted on this page with an updated date. Continued use of our Services after changes means you accept the new Terms.

These Terms are governed by the laws of the United Kingdom of Great Britain and Northern Ireland, without regard to its conflict of laws principles.

Modern Slavery and Human Trafficking statement

Statement as required under s54, Part 6, of the Modern Slavery Act^[1] 2015 for the 2026/2027 financial year.

1. Introduction

Up Digital Risk Limited is committed to ensuring that its business dealings are carried out in compliance with the relevant laws and, in doing so, we endorse the implementation and promotion of ethical business practices to protect workers from being abused and exploited.

The Company is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.

2. Organisation Structure

This statement covers the activities of Independent Broking Solutions Limited and its Appointed Representative Network.

3. Relevant Policies

The Company operates a number of policies that mitigate the risk of modern slavery and set out steps to be taken to prevent slavery and human trafficking in its operations.

4.1 Whistleblowing

The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact our Compliance Officer Jonathan Sprules in the full knowledge that all disclosures will be held confidential.

4.2 Supplier Chain Management

Whilst the Company exercises a vital role in the insurance distribution chain, it does not have a supply chain that is reliant on factories or other entities that would normally be associated with slavery or forced labour.

As a general rule, contractors and suppliers used by the Group are therefore not likely to be susceptible to this risk. However, we are mindful that others may not always uphold standards to the same level as Independent Broking Solutions Limited. Consequently, employees responsible for managing suppliers and others involved with the Group are, themselves, responsible for ensuring that our values and ideals are upheld. This continues to be a work in progress and we are strengthening our controls as new contracts are agreed. For example, serious violations by suppliers will lead to the termination of the business relationship.

4.3 Recruitment and Selection

The Company uses only, reputable employment agencies and personal contacts to source labour. All entities in the Group ensure appropriate controls are in place to ensure employees have the right to work and are therefore protected by employment legislation. This includes checking right-to-work documents, visas and passports.

The Company and its associated subsidiaries do not employ individuals that would be considered to be ‘child workers’. Young and inexperienced workers may be employed or given work experience, but they are subject to the rights and protections that we afford all workers.

Basic rights which we expect all workers to enjoy, include:

• The right to a reasonable wage
• The right to a safe working environment
• The right to an appropriate level of holiday and cover for period of sickness
• The freedom to complain directly via our whistleblowing policy free of charge, if they believe that they are not being fairly treated or have any other concerns.

5. Right of Audit

All offices in the Group are subject to periodic audits. Core audit work includes an assessment of the basic working conditions of our staff and consideration of our ability to oversee controls discharged by third party suppliers.

[1] References in this Statement to the “Act” are references to the Modern Slavery Act 2015.