Who is responsible for your data?
Introvisory Ltd, trading as InsuranceFX, is the controller of personal data collected through this website and our services.
InsuranceFX and CommercialFX are trading names of Introvisory Ltd. There is no separate InsuranceFX company, so data you give to InsuranceFX is held by Introvisory Ltd from the start.
Introvisory Ltd, 105-107 Farringdon Road, London EC1R 3BU. Company number 11003625. ICO registration number to be confirmed. To contact us about your data, call 020 7566 0044 or email us.
What data do we collect?
Business contact details, information about your firm and its currency flows, conversion data you share for a cost review, and basic technical data when you send a form.
- Contact details: name, role, firm, work email and phone number.
- Firm details: firm type, domicile, the flows you need help with, currencies, approximate annual volume, current provider type and, if you tell us, your firm's client money position.
- Quote details: currency pair, amount, timing, the type of flow and settlement needs.
- Conversion data for cost reviews: dates, times, currency pairs, amounts, rates and fees.
- Call requests: preferred dates and times.
- Technical data sent with a form: IP address, browser user agent and the page you came from, kept to help prevent fraud and abuse.
- Analytics data, unless you turn analytics off: pages viewed and how the site is used, collected by Google Analytics 4.
Most of this is about your firm rather than about you. The personal data is mainly the contact details of the people we deal with. We do not collect KYC documents: those go from your firm to the provider directly.
Do you need any policyholder or claimant data?
No. We never need the names, addresses or policy details of policyholders, claimants or beneficiaries, and we ask you to remove them before you send anything.
A cost review needs only the date and time, currencies, amounts, rates and fees of each conversion. Please also take out policy numbers, claim references, the names of cedants or counterparties and bank account numbers. If a file reaches us with that kind of data in it, we delete the file, tell you and ask for a clean copy.
Once your firm is onboarded, any payee details the provider needs to make claims payments go from your firm to the provider directly under the provider's own privacy notice. They never pass through InsuranceFX.
Why do we use it, and on what lawful basis?
Mostly to provide the service you asked for and to run our business, which are our legitimate interests or steps you have asked us to take before a contract.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Replying to enquiries and call requests | Contact details, message, preferred times | Legitimate interests in responding to business enquiries |
| Running blind quotes | Quote details, firm type and domicile | Steps you ask us to take before entering into a contract, and legitimate interests |
| Running cost reviews and rate creep checks | Conversion data, contact details | Steps you ask us to take, and legitimate interests |
| Introducing your firm to a provider | Contact details and the firm details the provider needs | Your instruction, and legitimate interests |
| Paying referral partners | Your firm's name and whether an introduction went ahead | Legitimate interests in meeting our agreements with firms that refer clients to us |
| Preventing fraud and abuse of our forms | IP address, user agent, referrer | Legitimate interests in keeping our services secure |
| Occasional guides and updates to business contacts | Name, work email | Legitimate interests, with an opt-out in every email |
| Website analytics | Analytics cookie data | Legitimate interests in understanding how the site is used, with a one-click opt-out |
| Meeting legal and regulatory duties | Records of enquiries, approvals and complaints | Legal obligation |
Who inside Introvisory sees our data?
Only the people who work on InsuranceFX and Introvisory's compliance oversight.
Our records sit in one database used by Introvisory's CommercialFX brands, with each record marked to the brand it came through. Uploaded conversion files are kept apart from that database, encrypted, and can be opened only by the team running your review.
What does a provider receive when we introduce you?
Only what it needs to start onboarding your firm, and only once you have chosen it and asked us to introduce you.
That is usually the name, role, work email and phone number of your contact, your firm's name and the details of the requirement we quoted. The provider then becomes a separate controller of that data and its own privacy notice applies. It collects identity and KYC information from your firm directly, and we do not see or keep those documents. Providers you did not choose receive nothing that identifies you.
Who else do we share it with?
Only our own service providers, a referral partner where one introduced you, and anyone the law requires.
- Companies that host our website, database and email, under contracts that require them to protect the data.
- Google, which processes analytics data on our behalf, unless you turn analytics off.
- A captive manager, broker or other firm that referred you to us, which we tell whether an introduction went ahead so any referral fee can be paid. We do not share your quotes or review results with them unless you agree.
- Regulators, law enforcement or courts where the law requires it.
We do not sell personal data.
How do blind quotes protect your firm's identity?
Providers receive the requirement, not the requester. They see the currencies, amounts, timing, the type of flow and settlement needs, your firm type and domicile, but not your firm's name, your clients, your markets, your name or your contact details.
We also take out anything in your notes that could identify your firm, its clients or its markets. Your identity is shared only when you ask us to introduce you to a particular provider. How blind quotes work
How long do we keep data?
Only as long as we need it. Uploaded conversion files are deleted automatically 90 days after we receive them.
| Data | How long we keep it |
|---|---|
| Uploaded conversion files for cost reviews | 90 days from receipt, then deleted, or sooner if you ask |
| Conversion details typed into the website | 90 days from receipt, then cleared |
| Cost review reports we send you | 6 years, so later rate creep checks can be compared with them |
| Enquiries that do not lead to an introduction | 2 years from the last contact |
| Records for firms we introduce | 6 years after the relationship ends |
| IP address and user agent sent with forms | 12 months |
| Complaints | 6 years after the complaint is closed |
How do you protect conversion files and other data?
Uploaded conversion files are encrypted when stored, kept outside the website itself and deleted on schedule, and access is limited to the InsuranceFX team.
Forms are protected against automated misuse and the website uses an encrypted connection. We never ask for bank log-ins, account numbers or payment instructions through the website. Each scheduled deletion is logged, so we can tell you when your file was removed.
Do you use analytics?
Yes. We use Google Analytics 4 for statistics only, to count visits and see which pages are useful, and you can turn it off with one click.
Google signals, advertising features and ad personalisation are switched off, so the data is not used for advertising. If your browser sends a Global Privacy Control signal we treat it as an objection, and Google Analytics collects nothing from your visit. The switch is at the foot of every page and on our cookie policy, which lists each cookie involved.
Is data sent outside the UK?
Only analytics data, unless you turn analytics off, because Google may process it outside the UK.
Google relies on the UK International Data Transfer Addendum or the UK Extension to the EU-US Data Privacy Framework for these transfers. Our website and database are hosted in the UK. When we introduce your firm to a provider, the provider tells you where it processes data in its own privacy notice.
What are your rights?
You can ask to see, correct or delete your data, object to how we use it, restrict it, or take a copy, and you can turn analytics off at any time.
To use any of these rights, call 020 7566 0044 or email us. We will reply within one month. You can turn analytics off with one click using the switch in the footer or on our cookie policy.
How do you complain about how we use your data?
Tell us first and we will try to put it right. If you are not satisfied, you can complain to the Information Commissioner's Office.
See our complaints page for how we handle data protection complaints. The ICO can be contacted at ico.org.uk/make-a-complaint or on 0303 123 1113.
Will this policy change?
If it does, we will update this page and the date at the top.