Privacy Policy

Our commitment to your data privacy.

Last updated: November 2025

By entrusting us with your personal data, we are building a relationship of trust together because we want to prove ourselves worthy.

Aspire Insurance Advisers Ltd is committed to protecting your personal information and respecting your privacy. We process personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This privacy notice explains how we collect, use, and safeguard your personal data when you interact with our services. Aspire Insurance Advisers Ltd ensures that appropriate security measures are in place to protect your information and uphold your privacy rights.

Our personal data processing policy is based on the following six principles:

Lawfulness of processing: personal data collection and processing are legitimate and based on a legal basis identified in accordance with the objective (or purpose) and the context in which it is processed.

Purpose of processing: we do not use your personal data for any other purpose. We collect your personal data strictly for the defined purposes.

Period for keeping personal data: we establish a limited period for keeping your personal data, in accordance with the purposes and lawfulness of processing.

Security and privacy: We strive to protect and secure your personal data. We take whatever measures needed to ensure a level of security appropriate to the risk between the controller and the processor. In assessing the appropriate level of security, we take into account the risks of each type of processing (sensitive data, purpose of processing).

Transparency: When we collect your personal data, we will tell you how we intend to use it and if we need to share it with other parties.

Individuals’ rights: You shall have the right to obtain from us confirmation of your personal data and, where appropriate, the right to correct them. Where applicable, you can request the erasure, portability, restriction of processing or to object to this processing. You can also withdraw your consent at any time, and access to your personal data. For more information, please see the ‘’Your rights as Concerned Person’’ section below.

You can find our obligations and your rights in the General Terms and Conditions of Use on our website as well as in the Privacy policy.

These documents explain how we process, notably, collect, use and store your personal data.

Objective

The purpose of this Privacy Policy is to inform you about the collection, processing and use of your personal data, and the rights you have in connection with the use of the websites and online platforms, the subscription and the servicing of insurance policies designed, distributed and/or managed by Aspire Insurance Advisers Ltd.

Aspire Insurance Advisers Ltd reserves the right to modify this Privacy Policy at any time, due to changes to its websites and online platforms, configuration changes, changes within Aspire Insurance Advisers Ltd. or regulatory changes, or for any other legitimate reason.

1. DEFINITIONS

For the purposes of this Privacy Policy, the following terms – whether capitalised or not – will have the following meanings:

Insured Party: the physical person to whom the coverages of an insurance policy apply (whether or not the said person is the subscriber), the said policy being designed, distributed and/or managed by Aspire Insurance Advisers Ltd.

Personal Data or Personal Information: means any information which relates to a person and allows that person to be identified either directly or indirectly. This information may include, but is not limited to, your name, mailing address, e-mail address and telephone number. Personal Data does not include information that has been anonymised or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information. Under the UK GDPR, Sensitive Information (referred to as “Special Category Data”) includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for identification purposes, data concerning health, or data concerning a natural person's sex life or sexual orientation.

Concerned Person (Data Subject): refers to an identified or identifiable physical person; is deemed to be an “identifiable physical person”, i.e. a physical person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural or social identity of that physical person.

Personalised Space: means a space on a Site accessible to Insured Parties under the conditions provided for in the General Terms and Conditions of Use of the Site and by means of a username and a password.

Controller: means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Services: refers to the Aspire Insurance Advisers Ltd services for brokers and companies as well as the Site.

Site: refers to the Aspire Insurance Advisers Ltd website accessible at www.aspireinsuranceadvisers.com and online platforms, including public spaces accessible to all Users, and Personalised Spaces through which Aspire Insurance Advisers Ltd provides Insured Parties with services under the terms of insurance policies designed, managed and/or distributed by Aspire Insurance Advisers Ltd. The Sites, including the Personalised Spaces, are subject to the General Terms and Conditions of Use (CGU) which this Privacy Policy supplements.

Processing or Process: means any operation or set of operations performed using processes that may or may not be automated, applied to personal data or sets of personal data, such as the collection, recording, structuring, storage, adaptation or alteration, retrieval, consultation, use, or disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. YOUR CONSENT TO COLLECTION, USE AND DISCLOSURE

Aspire Insurance Advisers Ltd collects, uses, discloses and retains personal information that you provide to us with your consent.

For more information, please click here.

We collect, use and disclose your Personal Data with your consent or as permitted or required by law. How we obtain your consent (i.e. the means we use) and the form of it (i.e. either express or implied) will depend on the circumstances, as well as the sensitivity of the information collected. If you choose to provide Personal Data to us voluntarily, we will assume that you consent to the collection, use and disclosure of such Personal Information as outlined in this Privacy Policy.

We will seek your consent at the time your Personal Data is collected. The consent you give is valid only to achieve the purposes for which it was requested. In the situation where we would want to use your Personal Information for a purpose other than the one identified at the time of collection, we will seek your consent prior to such new use.

You may withdraw your consent to our collection, use or disclosure of your Personal Data at any time by contacting us using the contact information in the “Contact Us” section below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

If you provide Personal Data about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy.

3. PERSONAL DATA PROTECTION

3.1 Identity and Contact Details of the Controller

Personal Data is collected and processed by:

Aspire Insurance Advisers Ltd
Dawson House, 5 Jewry Street, London, EC3N 2EX

3.2 Collection Methods

When you visit our site, we collect some personal information about you.

For more information, please click here.

Your Data is collected directly by Aspire Insurance Advisers Ltd when you enter your Data in the contact forms, questionnaires and other means provided to you as part of use of the Site’s services (recruitment, free callback request, estimate request, Personalised Space, etc.), or as part of a membership or subscription form to one of our services and/or products.

Your Data may also be collected indirectly during your browsing on the Site (for example, via cookies), or by other companies of XN Holdings Inc., or may be transferred by insurers, client companies or our partner brokers within the scope of the fulfillment of insurance policies, and for the purposes of using the services of Personalised Spaces, or by recruitment firms as part of a recruitment procedure.

Within the scope of collection, the following Data is processed:

Identity data (last name, first name, address, telephone number, email address, date of birth, country of origin, etc.);

National Insurance / Social Security Number for products which earn investment income, in order to comply with the presiding revenue authority’s income reporting requirements. Providing your social insurance number is optional and will only be used for verification purposes to ensure your account privacy and will enable Aspire Insurance Advisers Ltd to keep your information separate from that of other customers with a similar name.

Data pertaining to family, economic, heritage or financial situation, personal life and living conditions, having a connection with the commercial relationship (civil status, marital status, information on spouse and children, etc.);

Data pertaining to professional and non-professional life, having a connection with the commercial relationship (occupation and professional field, information on the employer, website, name of the previous insurer and the previous insurance policy, information on movable assets such as vehicles or objects, type of policy desired, country of expatriation/secondment, affiliation to a health insurance fund, welfare plan, desires/preferences concerning an insurance policy, etc.);

Health data (information about hospitalisations, about needs for optical appliances, dental care, and about planned treatments, etc.);

Data for tracking the commercial relation (data pertaining to the organisation and the handling of competitions or draws, and whatever promotional operation, loyalty actions, prospection, studies, surveys, product tests, data about a person’s contributions, comments, explanations about how the User came to know about Aspire Insurance Advisers Ltd, reasons for a contact request, etc.);

Data pertaining to the access to Personalised Space: registration data such as access code and access data such as user name and password;

Location and connection data;

Data pertaining to the selection of people (career path, job offer sought, etc.), notably to join the appointed broker list: first and last name, brokerage firm, email, phone number, city, county and any other information the Concerned Person may give;

Data pertaining to the determination and assessment of risk and the management of claims and benefits;

Where appropriate, Data pertaining to offenses, criminal convictions and precautionary measures concerning the Insured Party, concerned parties or parties to a policy.

3.3 Purposes and Legal Basis of Data Processing

We process your personal data to provide and improve our services to you. We also use it to meet our legal obligations.

For more information, please click here.

Your Personal Data is processed by Aspire Insurance Advisers Ltd for the following legal purposes and on the following legal bases.

Purpose (objective sought)	Legal bases (basis or reason for the Processing)
Provide the Services, which includes providing with the services such as investigation or handling claims, products, and functionality offered through our Services and fulfilling your requests	Performance of a contract
Authenticate your account credentials and identify you, as necessary to log you into the Services and ensure the security of your account.	Performance of a contract
Communicate with you about your account or use of our Services, products, and/or functionality.	Consent
Management of access, security, maintainability, evolutions and audiences of sites and platforms accessible online (Google Analytics)	Aspire Insurance Advisers Ltd’s legitimate interest in ensuring the availability and proper functioning of its Sites, the improvement of its Services as well as the promotion of its businesses through its Sites
Recruitment Management	Aspire Insurance Advisers Ltd’s legitimate interest in recruiting people for the purposes of its business
The conclusion, management (including commercial) and fulfillment of Insured Parties’ insurance policies	Performance of a contract
Commercial prospection (including commercial prospecting and loyalty actions, development of sales statistics, contact requests, information or estimate requests, rights management or management of Users’ and Insured Parties’ opinions about products, services or content, etc.)	Consent
Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity.	Legal obligations and Aspire Insurance Advisers Ltd ’s legitimate interest in being able to protect itself against fraud
Comply with our policies, procedures and legal obligations, including complying with law enforcement or government authority requests, addressing litigation-related issues, and exercising rights or obligations conferred by law.	Legal obligation
As otherwise consented to by you for a new purpose, notably regarding sensitive information and as required or permitted by applicable law.	Consent or legal obligation.
The processing of Data pertaining to offenses, convictions or precautionary measures: provided for by legal, regulatory and government provisions, whether at the time of subscription to the policy, or during its fulfillment and, falling within the scope of litigation pertaining to Aspire	Legal and regulatory obligations Aspire Insurance Advisers Ltd legitimate interest, with regard to its business, in ensuring the recognition, exercising or defense of its rights or your rights in law.

3.4 Mandatory/Optional Nature of the Collection

Aspire Insurance Advisers Ltd informs you when the provision of an information item is mandatory (including when due to a legal, regulatory or contractual obligation, or simply in order to process your request or respond to you). If you do not provide this so-called “mandatory” information, Aspire Insurance Advisers Ltd may be unable to respond to the request or form in question or to provide the Services.

Fields on a form that are not specified as mandatory are left to your discretion. It is up to you to choose to whether to fill them in or not.

3.5 Data Recipients

We may provide your personal data to our service providers and partners to provide our services.

For more information, please click here.

Your Data is primarily intended for Aspire Insurance Advisers Ltd. However, with your consent or as otherwise permitted under the law, it may also be transferred, for the purposes of providing the Services, to Aspire Insurance Advisers Ltd insurance and reinsurance partners, to Aspire Insurance Advisers Ltd healthcare networks and to XN Holdings Inc. companies.

As part of the Processing, Aspire Insurance Advisers Ltd may also transfer your Data to service providers, agents and suppliers, which may be located outside the UK, to complete internal operations of the Site, or for any operation related to Aspire Insurance Advisers Ltd business, for the purposes specified in Article 3.4 herein, and only to the extent necessary for the accomplishment of the tasks entrusted to them. These service providers, agents and suppliers are required to maintain the confidentiality and security of your Data, and to implement the appropriate measures.

If Personal Data are outside your country, they are subject to the laws of the country in which they are located and may be disclosed to governments, courts or law enforcement or regulatory agencies of that other country and in accordance with the laws of that other country. However, our practices regarding your personal information will at all times be governed by this Policy as well as appropriate safeguards such as the standard contractual clauses of the UK. Aspire Insurance Advisers Ltd may also transfer your Data if such disclosure is required by law, a regulatory provision or a court order, or if such disclosure is reasonably necessary to comply with court proceedings and respond to any complaints or protect the security of your Data or your or Aspire Insurance Advisers Ltd rights.

When we disclose your personal information to service providers, we take reasonable actions to ensure that the rules set out in this Policy are followed.

In the event of a change of ownership, sale, amalgamation, liquidation, reorganisation or acquisition of Aspire Insurance Advisers Ltd, in whole or in part, your personal information may be transferred as part of the transaction.

3.6 Location of your personal data

Your personal data is currently hosted in Canada and can be transferred to third parties outside of your country of residence.

For more information, please click here.

Your personal data is stored and processed in data centers located in North America.

However, your personal data may be transferred to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. To guarantee an adequate level of protection of your Personal Data, the transfers will at all times continue to be governed by this Privacy Policy and by applicable laws. Appropriate safeguards, such as UK-approved Standard Contractual Clauses, will be implemented to ensure an adequate level of protection of your Personal Data.

3.7 Data Stored Period

We will only keep personal information for as long as reasonably necessary to fulfill the relevant purposes set out in this Policy Privacy and in order to comply with our legal and regulatory obligations. If you would like further information regarding the periods for which personal information will be kept, please contact us at enquiries@aspireinsuranceadvisers.com.

3.8 Opting Out of Communications

If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us, you may log-in to your account and make changes to your communication preferences. You may also opt out by contacting us directly.

We endeavor to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

3.9 Your Rights as Concerned Person

You have the right to file a complaint with the Information Commissioner’s Office (ICO), the UK’s data protection authority.

We will take steps to ensure that your Personal Information is kept as accurate, complete and up-to-date as reasonably necessary. We will not routinely update your Personal Information, unless such a process is necessary.

To make sure that the information we hold on you is accurate and up to date, please inform us promptly of any change in your Personal Information.

On written request and subject to proof of identity, you may consult the Personal Information that we have collected about you, and ask that any necessary corrections be made, where applicable, as authorised or required by law. The information required to identify you will only be used for this particular purpose.

In addition, under certain circumstances, you have the following rights:

Right to withdraw consent

Right to Erasure

An Individual has a right to complete erasure or deletion of Personal Information if any of the following situations apply:

Where Personal Information is no longer necessary in relation to the purpose for which it was collected or processed.
Where an Individual withdraws his/her consent to the processing and there is no other lawful basis for processing the information.
Where an Individual objects to the processing and there is no overriding legitimate ground for continuing the processing.
Where an Individual objects to the processing where their Personal Information is being processed for direct marketing purposes.
Where an Individual’s Personal Information has been unlawfully processed.

However, the right to erasure will not apply where processing is necessary for

Exercising the right of freedom of expression and information;
Compliance with a legal obligation, the performance of a task carried out in the public interest or in the exercise of official authority;
Reasons of public interest in the area of public health;
Archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;
Establishment, exercise or defence of legal claims.

Automated decision system

You have the right to object, on grounds relating to his or her particular situation, at any time to processing of your personal data based on Aspire Insurance Advisers Ltd’s legitimate interest, including profiling based on those provisions. Aspire Insurance Advisers Ltd will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

Right to Portability

An Individual may request that Personal Information held about them be communicated to them in a structured, commonly used and machine-readable format and, in certain circumstances, that this Personal Information be communicated to a third party without hindrance, if the following conditions are met:

Personal Information processing;
Processing by automatic means;
Processing based either on consent or on contract.

Right to Object to the Processing

An Individual has a right to objection:

at any time to processing of personal data concerning him or her which is based processing is necessary for the performance of a task carried out in the public interest or if the processing is necessary for the purposes of the legitimate interests pursued by Aspire Insurance Advisers Ltd, including profiling based on those provisions.

for direct marketing purposes.

Aspire Insurance Advisers Ltd will honor an Individual’s request unless we can demonstrate compelling legitimate grounds for the processing which override an Individual’s interests, rights, and freedoms or is necessary for the establishment, exercise, or defense of Aspire Insurance Advisers Ltd’s legal claims.

Right to Restrict Processing

An Individual has a right to restrict processing (i.e. limit the processing of stored Personal Information in the future) where one of the following conditions applies:

accuracy of Personal Information is contested;
processing of Personal Information is unlawful and an Individual prefers restriction of processing instead of erasure;
Aspire Insurance Advisers Ltd no longer requires the Personal Information for intended processing purposes but such Personal Information is necessary for the establishment, exercise or defence of legal claims; or

An Individual objects to processing of Personal Information, pending the verification whether the legitimate grounds of Aspire Insurance Advisers Ltd override those of the Individual.

If you want to learn more about your rights under the UK GDPR, you can visit the Information Commissioner’s Office (ICO) website.

You also have the right to lodge a complaint with the relevant data protection authority.

3.10 Automated Decision-Taking

In the event of non-payment of the Insured Party’s premiums, the follow-up, notice and delisting procedure is automated.

Since this processing gives rise to an automated individual decision, you have the following rights under the terms of the applicable Data Protection Regulations:

The right to request the involvement of a person to verify the Processing in question and ensure the compliance of the decision applied to your situation;

The right to challenge a decision taken automatically by Aspire Insurance Advisers Ltd’s systems, by sending your request to your usual contact at your management unit (MU) or the Aspire Insurance Advisers Ltd Complaints Department, at the following address: enquiries@aspireinsuranceadvisers.com

3.11 Data Security and Privacy

Use of Personal Information by Employees

Certain employees, agents, brokers and producers will be provided with information about an insured in order to serve that insured’s needs and provide the insured with information regarding specific products. These persons are instructed by Aspire Insurance Advisers Ltd to use strict standards of care in handling the personal, confidential information of Aspire Insurance Advisers Ltd.’s insureds. The importance of protecting your information has been conveyed to Aspire Insurance Advisers Ltd’s employees, and they are required to adhere to stringent policies and procedures relating to the safeguarding of your information. Electronic, physical, and procedural safeguards have been implemented in order to efficiently protect your information. Employees, agents, brokers and producers who do not conform to Aspire Insurance Advisers Ltd's confidentiality rules are subject to disciplinary and/or contractual sanctions that include dismissal.

Aspire Insurance Advisers Ltd’s policy is to limit access to customer information to those who need it to serve customers’ insurance needs.

Data security

Within the scope of its business, and in compliance with the applicable Data Protection Regulations, Aspire Insurance Advisers Ltd undertakes to take all appropriate technical and organisational measures to ensure the security, availability, integrity, authenticity and confidentiality of your Personal Data and the resilience of its information systems.

In the event of any suspicion of risk, loss of your login credentials, or any other event that may entail risks to the Sites and Personal Data, please contact Aspire Insurance Advisers Ltd without delay and, if the case concerns a loss or disclosure of your login credentials for your account and Personalised Space, we recommend that you immediately request a new password in your Personalised Area, in the “Change Password” tab.

Risk Related to Internet

Access to your account is secured by the latest Internet security protocol, provided that your web browser supports 256-bit encryption. The latest versions of Internet Explorer, Google Chrome, Mozilla Firefox, Microsoft Edge or Apple Safari browsers all offer this feature. These browsers inform you when you are entering a secure environment.

Although every effort is taken to ensure no one else will see or obtain your personal data, complete confidentiality and security is not yet possible over the Internet. Internet use and communication is subject to interception, loss and alteration. You acknowledge and agree that Aspire Insurance Advisers Ltd shall not be responsible for any damages you may suffer as a result of the transmission of confidential or sensitive information over the Internet, and that all such communications will be at your own risk.

Protection of Personal Information of Children

Our Services are not intended for any minor individual (“children”). If you are a minor under the laws applicable to your place of residence, please do not provide us with any personal information without the express consent of a parent or guardian.

We do not voluntarily collect personal information from minor children. If you are a parent or guardian and you know that your children have provided us with personal information, please contact us. If we learn that we have collected personal information from minor children without verification of parental consent, we will take steps to remove that information from our servers.

4. COOKIES AND OTHER MEANS OF TRACKING

We may also collect and Process Information about your visit to this website, such as the pages you visit, the website you came from and the searches you perform. We may use such information to help improve the contents of the site and to compile aggregate statistics about people using our site for our internal usage statistics and market research purposes.

In doing this, we may install "cookies" or similar technologies that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. Cookies are created and stored on the user's computer, phone or other devices when the user's browser loads a particular website. Every time the user goes back to the same website, the browser retrieves and sends this "cookie" file to the website. Cookies are useful because they serve key purposes like helping a website remember your preferences and settings, performing analytics to improve services, serving you relevant content or advertisements and authenticating you on the websites. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie, this will enable you to decide if you want to accept it or not. You can also refuse cookies altogether. However, if you do not accept our cookies, you may not be able to use all functionalities of our website. When you visit our websites, you may be presented with a cookie-setting banner that allows you to manage the settings and accept or deny the cookies. It is legally permitted to store cookies on your machine if they are essential to the operation of the website, but for all other types of cookies we need your permission to do so. You have the option to consent to the use of cookies while visiting the website for the first time when a cookie banner will be shown or manage these settings anytime later by clicking the Cookie Settings link in the footer of the website. These cookie settings give you the option of accepting or denying your consent to every category of cookies (with the exception of the necessary cookies which are always active). Please refer to our Cookie Settings to learn more about what types of cookies we use (the purpose they serve, their lifespan, and their provenance) and how you can manage your preferences.

5. WHEN DOES THIS POLICY NOT APPLY?

Do take note that if you access any third-party link or website from our Services, you may need to refer to the privacy policies of such third parties. Aspire Insurance Advisers Ltd does not endorse and is not responsible for the information or privacy practices of websites or services owned by third parties.

6. CONTACT US

If you wish to contact us regarding how we use your Personal Data or you wish to exercise your data privacy rights, please email us at: enquiries@aspireinsuranceadvisers.com

Privacy Policy

Our commitment to your data privacy.

Objective

1. DEFINITIONS

2. YOUR CONSENT TO COLLECTION, USE AND DISCLOSURE

For more information, please click here.

3. PERSONAL DATA PROTECTION

3.1 Identity and Contact Details of the Controller

3.2 Collection Methods

For more information, please click here.

3.3 Purposes and Legal Basis of Data Processing

For more information, please click here.

3.4 Mandatory/Optional Nature of the Collection

3.5 Data Recipients

For more information, please click here.

3.6 Location of your personal data

For more information, please click here.

3.7 Data Stored Period

3.8 Opting Out of Communications

3.9 Your Rights as Concerned Person

Right to withdraw consent

Right to Erasure

Automated decision system

Right to Portability

Right to Object to the Processing

Right to Restrict Processing

3.10 Automated Decision-Taking

3.11 Data Security and Privacy

Use of Personal Information by Employees

Data security

Risk Related to Internet

Protection of Personal Information of Children

4. COOKIES AND OTHER MEANS OF TRACKING

5. WHEN DOES THIS POLICY NOT APPLY?

6. CONTACT US

COMPANY

PRODUCTS

LEGAL

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