Consumer Terms of Business

Tapwell Pub Insurance is a trading name of Grow Money Group Limited. Grow Money Group Limited is an Appointed Representative of Movo Partnership Ltd, which is authorised and regulated by the Financial Conduct Authority. Our Financial Services Register number is 823503. These details can be checked on the Financial Services Register by visiting the FCA's website at https://register.fca.org.uk/ or by contacting the FCA on 0300 500 8082.

We are permitted to arrange, advise on, deal as an agent of insurers, assist in claims handling, help with ongoing changes, introduce to an insurer or finance provider(s) and arrange lending facilities, collect debt and administer debts in respect of general insurance policies on behalf of our clients.

We have access to leading insurers and often we select your insurance product from a wide range of insurers; however there are times when we use a select panel of insurers or finance providers. Please ask us if you would like a list of these insurers. At our discretion, we offer clients the option to pay by instalments through a finance provider. We will always advise you of our selection range prior to you committing to purchase an insurance policy or take out a finance agreement. In certain circumstances we may use the services of another intermediary to place your insurance and, in that event, we will always advise you of the name of that intermediary.

Upon assessment of your requirements, we will make a recommendation for a particular insurance product. Our advice will be confirmed in a demands-and-needs statement which will clearly state the reasons for our recommendation. In some circumstances we may not provide advice — for example, if we renew your insurance cover with your existing insurer without re-broking, or if we simply provide you with information on a product. If we do not provide you with advice, we will always make this clear in our documentation.

We will exercise reasonable skill and care in the performance of all our services for clients, but we cannot be held responsible for advice, recommendations or actions that are based upon incorrect or inadequate disclosure of material information by clients or their agents. The liability of Grow Money Group Limited, howsoever arising, shall not exceed in the aggregate the sum of £2,000,000. These limitations shall not apply to liability for personal injury or death caused by our negligence, for fraud or fraudulent misrepresentation, or in circumstances which cannot be excluded by law.

We reserve the right, at our discretion, to make an administration charge, a table of which is available upon request as these can differ. We will provide you with a breakdown of any fee to be charged at quotation. Fees may be applicable in situations including, but not limited to:

• Arranging new policies
• Mid-term adjustments
• Renewals
• Replacement or duplicate certificates or cover notes

Mid-term cancellations and other refunds are refunded net of commission. In addition, we may charge an administration fee for any mid-term adjustments.

We receive commissions from insurers when we place your insurance policies, and this commission rate can vary. Occasionally we may arrange a policy on which we earn no commission and, in these cases, we will advise you of the arrangement fee before you take the policy out. These fees will be paid to us upon acceptance and inception of the policy by the insurer; we will confirm the amount of the fee as part of your quotation. We may also make additional charges specific to the arrangement and servicing of certain policies, but these will always be advised to you in advance.

These fees may be subject to change and where this is the case you will always be advised of the actual fee in writing.

You must take reasonable care to provide complete, accurate and honest answers to the questions we ask when you take out, make changes to, and renew your policy. Please also tell us if there are any changes to the information set out in your policy documentation.

If any of the information changes after you purchase or renew your policy and during the period of your policy, please provide us with details. If any of the information provided by you is not complete and accurate:

• Your insurer may cancel your policy and treat it as if it never existed;
• Your insurer may refuse to pay any claim;
• Your insurer may not pay any claim in full;
• Your insurer may revise the premium and/or change the compulsory excess; or
• The extent of the cover may be affected.

You should keep a record (including copies of letters) of all information provided for future reference.

We will write to you in good time before your renewal date, offering your terms; in situations where we are not inviting renewal, we will tell you. Renewal of the contract is based on the information you supplied when we arranged your current contract along with any amendments you have made during the period of cover. It is important that you tell us about any changes to your requirements.

Where we offer you renewal terms and your insurance is paid by continuous monthly direct-debit instalments, in the absence of a response from you, some insurers will deem this as your consent to renew automatically.

You must provide the premium due in cleared funds in accordance with the amounts and dates specified in our payment options schedule. Failure to meet the payment date may lead to insurers cancelling your policy.

Please refer to our payment options schedule for full details on how to make a payment. Please note that cover will cease if you fail to keep up payments under a credit agreement. Many insurers provide a 24-hour helpline in respect of claims — please refer to your policy documents for contact details.

Your policy document will provide you with specific information on your full rights to cancel your insurance. A personal policy which lasts for more than one calendar month offers you the facility to cancel cover (providing there have been no claims) within 14 days from the policy start date or the date when you receive the full policy documentation from us or your insurers, whichever occurs later. You will be entitled to a refund of premium less our administration charge and a charge by your insurer for the time your insurance cover was in place.

Where you cancel your personal insurance outside the 14-day cancellation period, we reserve the right to charge for our time in providing you with advice and for the administration costs involved. This results in us retaining our original commission and fees.

For some insurance contracts, insurers will not provide refunds for mid-term cancellation of cover. We will tell you if this affects you. We do not provide refund payments of less than £25.

Grow Money Group Limited is not authorised to handle client monies; all client money is handled by Movo Partnership Ltd. Details of Movo Partnership Ltd are available on the FCA Register. Movo Partnership Ltd hold all client money in a trust account, the purpose of which is to protect you in the event of financial failure since, in such circumstances, general creditors would not be able to make claims on client money.

If Movo Partnership Ltd hold money on a client's behalf, it will be held in a trust fund that is separate from Grow Money Group Limited's own cash assets. These separate trust arrangements are commonly known as 'client money'. Regardless of any outside influences, funds will be paid to insurers who have granted risk transfer and have agreed to subordinate their interests in the trust to those of Movo Partnership Ltd non-risk-transfer clients.

Movo Partnership Ltd do not use client money to pay commission before they receive your premium. The trust arrangement they use for client money is known as a non-statutory trust; they may use premiums and claims monies they receive to fund other clients' premiums and claims — for example, they may pay a premium on to an insurer before they have received it from the client if they believe it is in that client's best interests.

Movo Partnership Ltd have agreements with some insurers (known as 'risk transfer agreements'). Under these agreements, the insurers are responsible to you for any premium you have already paid to us, and remain responsible for premium refunds or claims payments until those are received by you. Where Movo Partnership Ltd do not have risk transfer agreements in place, the client money they hold will still be protected within the non-statutory trust.

When Movo Partnership Ltd hold client money on trust for you, this gives rise to fiduciary duties upon them that will not be discharged until the client money is deemed to have reached the insurer or product provider. Without affecting those fiduciary duties, in some cases they may pass client money to another intermediary, including ones outside of the United Kingdom where different legal and regulatory conditions apply. If you are a consumer, you can ask them to pass your money to an intermediary outside of the UK or in a particular country.

We will collect and store your personal and financial information, which will be handled in accordance with the UK GDPR and the Data Protection Act 2018. For the purposes of data protection legislation, we are the data controller. We will process your data in accordance with articles 6(1)(b), 6(1)(c) and 9(2)(a) of the UK GDPR to ensure proper performance of our agreement with you and to comply with our legal obligations.

We will use your name, address, email, contact number, date of birth and financial information to provide our services to you and verify your identity, and this may require us to pass your personal information to our group companies, electronic verification providers, product providers or other financial firms such as lenders, banks, insurers, fund managers and platform providers. Should you decide not to proceed with our services, we will delete your personal information.

We may be required to pass on your personal information to the FCA, Financial Ombudsman Service (FOS) or the Financial Services Compensation Scheme (FSCS) to help with an investigation or complaint, or other authorities as required by law. We may need to collect sensitive personal data — including information about your health, ethnic origin or criminal prosecutions — from third parties such as employers, credit reference agencies, fraud prevention agencies and other similar organisations in order to provide you with our services.

To help make sure you receive a competitive quotation, offer of appropriate payment options, protection against fraud and to verify your identity, both we and insurers may use publicly available data which we or they obtain from a variety of sources, including credit reference agencies and other external organisations. This search will appear on your credit report whether or not your application proceeds.

All information on our records relating to you will be treated as private and confidential and will only be disclosed to others such as our business partners, insurers, credit providers and other third parties who are directly involved in the normal course of arranging and administering your insurance. By accessing our sites and using our services, you consent to any such transfer of information to a third party. You may exercise your right to withdraw your consent to the processing of your sensitive personal data at any time, and to opt out of marketing information, by contacting us.

In accordance with data protection legislation, we are required to notify you of the legal basis upon which we process your personal data. We process your personal data for the following reasons: for performance of a contract we enter into with you; where necessary for compliance with a legal obligation we are subject to; and for our legitimate interests. We will also process your personal data (including sensitive personal data) where we have obtained your explicit consent.

We will retain any personal information only for as long as is necessary to fulfil the business purpose for which it was collected, and to comply with our legal obligations, resolve disputes and enforce our agreements. Under the UK GDPR you have the right to ask us for a copy of any personal information about yourself that we hold on our records. For further information on your rights please refer to the Information Commissioner's Office at www.ico.org.uk.

Our agreement may be terminated by either one of us giving 14 days' notice in writing to the other. You will be liable to pay for any outstanding transactions or adjustments prior to termination without any penalty fee, as long as these are settled immediately on termination. We will be entitled to retain any fees or commission payable in relation to business transacted prior to the date of termination.

These Terms of Business, which form our agreement with you, shall be governed by and construed in accordance with the laws of England and the exclusive jurisdiction of the English courts unless we agree with you otherwise.

Our aim is to provide all of our clients with an excellent level of service; however, we recognise that there may be occasions when you do not feel satisfied with the service you have received from us. Should you need to make a complaint, please contact the Complaints Manager by email at complaints@movopartnership.co.uk or by post at: Complaints Manager, Movo Partnership Ltd, Movo House, 33 Green Lane, Chislehurst, BR7 6AG.

We aim to resolve complaints within 3 business days following receipt; however if we can't, we will write to you within five working days to acknowledge your complaint and provide details of our complaint handling procedures and who is dealing with it. We aim to provide a final response within eight weeks from the date of receipt and, if we cannot, we will outline the reasons for the delay and provide an indication of when you can expect to receive a response.

If you are dissatisfied with our final response, or we have been unable to provide our final response to your complaint, you may be eligible to refer the matter to the Financial Ombudsman Service (FOS) free of charge. Details of the eligibility criteria can be found in our complaints procedure or on the FOS website at https://financial-ombudsman.org.uk. If you decide to refer your complaint to the Ombudsman, you must do so within six months of the date of our final response.

You can contact the FOS by calling 0800 023 4567 or 0300 123 9123, writing to Exchange Tower, London E14 9SR, or emailing complaint.info@financial-ombudsman.org.uk.

Both parties shall pay due regard to, and co-operate in respect of the observance of, any applicable international economic, financial or trade sanctions legislation.

We do not guarantee the solvency of any insurer we place business with. We are covered by the Financial Services Compensation Scheme (FSCS) for insurance mediation only; this does not extend to consumer credit broking. The FSCS is the UK's compensation fund of last resort for clients of authorised financial services firms. You may be entitled to compensation from the FSCS if the insurer cannot meet their obligations. This depends on the type of business and circumstances of the claim. Insurance advising and arranging is covered for 90% of the claim with no upper limit, although compulsory insurance is protected in full. Further details are available at www.fscs.org.uk.