This notice sets out how we, Animal Friends Insurance (AFI) and Red Sands Insurance Company (the Insurer) will use personal information we collect about you when you use this website or obtain a quote by telephone. Please read this notice with care as by using this site and/or applying for insurance by telephone you agree to be bound by its terms. If you do not agree to be bound by these terms you must stop using this website immediately.
You can ask for more information about our use of your personal information or complain about its use, by contacting our Data Protection Officer by post at No.1 The Crescent, Sun Rise Way, Solstice Park, Amesbury, SP4 7QA or emailing email@example.com with the subject Data Protection Officer.
We will be the data controller of your data for the purposes of the EU General Data Protection Regulation.
The privacy and security of your personal information is very important to us. We want to assure you that your information will be properly managed and protected whilst in our hands. Please read this notice carefully as it explains how we and/or your insurer, collect and use your personal information.
1. What information do we collect about you?
Sensitive personal information
For certain products we will need to process sensitive personal data such as details of your current or former physical or mental health. Where we collect any sensitive personal data about you, we will seek your consent prior to processing this.
We may collect personal information from the following sources:
• you or someone connected to you as part of a quotation or claim;
• price comparison websites, if you have obtained a quotation for a policy with us. The information you provide is shared with us and used for the purposes set out below. The information in this notice will apply in addition to any information given to you by that price comparison website about the use of your personal information;
• Third party service providers whom we have a relationship with.
• publically available sources of information, such as social media and networking sites;
• third party databases made available to the insurance industry as well as databases where you have given your permission to share information with a third party like us.
For more information about these sources, please contact the Data Protection Officer.
If you have provided information to us about someone else, you would have confirmed that you have the consent of these individuals to share their personal information with us. You should share this privacy notice with all individuals whose personal information you have shared with us as it may also apply to them.
2. How will we use the information we hold about you?
a)To provide you with services relating to an insurance quotation and/or insurance policy:
We collect and use personal information to allow us to give you a quote or to process your purchase of a policy. We also use your information in dealing with renewals and to improve our understanding of our products and services and of your interests. We will use it to manage your insurance policy, including claims handling, issuing policy documentation to you, and providing you with the services described in your policy documents.
Our assessment of your insurance application may involve an automated decision to determine whether we are able to provide a quotation and/or the price. The decisions involve the use of systems, such as our price rating and acceptability tools, and are dependent on the information you provide us (for example: post code, the breed of your pet and its age, whether you’ve had an insurance policy terminated) to produce a result as to whether we are able to provide a quotation and/or what the relevant price for your policy should be. If you object to an automated decision that is required to determine your insurance premium then we will be unable to provide you with an insurance quotation or renewal.
We will share your personal information with the insurer who will process the information to provide you with insurance cover. In the unlikely event we decide to change your insurance provider, in line with these terms and conditions, we will transfer this information to the new insurer.
We will provide you with a price for the insurance cover based on the information you provide. We reserve the right to refuse to offer insurance. All quotes are subject to acceptance by the Insurer whose decision is final.
Your personal data will be transferred to countries outside the EEA for the purpose of insurance product and service administration. It will at all times be held securely and handled with the utmost care in line with all principles of UK law.
b) Where we have a justifiable reason, such as:
• Keeping records about you and our correspondence with you as well as your current and past insurance policies and history of claims. This is so that we can appropriately and effectively manage our relationship with you as well as satisfy any legal and regulatory obligations we may have to keep such records.
• Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims or where we want to pursue any legal claims ourselves.
• Preventing and detecting fraud, financial crime and money laundering. We may use your personal information to prevent fraud and in doing so may:
– collect personal information about you from publically available sources (such as social media and networking sites);
– share your personal information with fraud prevention agencies. Your personal information may be checked with and recorded by a fraud prevention agency. If false or inaccurate information is provided and fraud is identified, details may be passed to the fraud prevention agency. We may share your personal information with operators or registers available to the insurance industry to check information you provide. We may pass information relating to your insurance policy and any incident to the operators of these registers, their agents and suppliers;
– use any personal information obtained about you, or anyone you have provided us information about, to carry out the above profiling activity as part of our investigations into fraudulent behaviour. Should fraud be identified as a result of such profiling activity, this could result in the rejection of an application for insurance, a claim and/or voidance of your policy.
• Providing sales information to third parties, such as a price comparison website, which you may have used to purchase a policy with us, so that we can fulfil our contractual responsibilities to them.
• Carrying out processes such as statistical and trend research and analysis which may include computerised processes which profile you. This is to better understand, predict and forecast our customers’ or prospective customers’ preferences and to improve the products and services we offer.
• Anonymising and combining the personal information you have given us to understand more about you, create new products and services and help us with our marketing.
• Recording and monitoring calls for training purposes, to improve the quality of our service, to help us deal with queries or complaints from you and to prevent and detect fraud and financial crime. We may also use CCTV recording equipment in and around our premises for monitoring and security purposes.
C) You have given us your permission:
If you have given us permission, your information may be used by us to keep you informed by post, telephone, email or other means, of other products, offers, and services we believe may interest you. We may use a third party to send you this information, either by email or SMS which means they will have access to some of your data.
3. Lawful basis for processing your information
We need to tell you the rights we have to process the personal information you give us.
We may process your information on the following bases:
• Such processing is necessary in order to enter into or perform a contract with yourself.This includes providing you with services relating to an insurance quotation and/or insurance policy such as:
– assessing your insurance application and arranging your insurance policy;
– managing your insurance policy including claims handling and issuing policy documentation to you;
– providing you with the services described in your policy documents.
- • You have consented to such processing.
- You have given us your permission:
– to use your personal information in order to use your sensitive personal information to make reasonable adjustments as a result of a disability you have told us about, or your religious beliefs;
– to contact you about other products and services that we may think would be of interest to you.
- • We have a legal obligation to perform such processing: Where we have a justifiable reason, such as:
– keeping records about you and our correspondence with you as well as your current and past insurance policies and history of insurance claims. This is so that we can appropriately and effectively manage our relationship with you as well as satisfy any legal and regulatory obligations we may have to keep such records;
– preventing and detecting fraud, financial crime and anti-money-laundering. We and/or your insurer may use your personal information to prevent fraud;
– sharing your personal information with fraud prevention agencies. Your personal information may be checked with and recorded by a fraud prevention agency. If false or inaccurate information is provided and fraud is identified, details will be passed to the fraud prevention agency. This information will be accessed and used by AFI, law enforcement agencies and other organisations to prevent fraud and money laundering.
• We have a legitimate interest to perform such processing such as:
– where we have an appropriate legitimate business need to use your personal information, for example developing and improving our products and services. We will ensure that our business need does not interfere with your rights and freedoms and does not cause you any harm.
4. Who do we share your personal information with?
• Your veterinary practitioner
• The Insurer and reinsurers.
• Our third party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers
• Other suppliers, providers of goods and services associated with this insurance and/or to enable us to deal with any claims you make.
• The Financial Ombudsman Service and regulatory authorities such as the Financial Conduct Authority and the Information Commissioner’s Office.
We may also disclose your personal information to other third parties where:
• we are required or permitted to do so by law or by regulatory bodies such as where there is a court order, statutory obligation or at the request of the Financial Conduct Authority or Information Commissioner’s Office; or
• we believe that such disclosure is necessary in order to assist in the prevention or detection of any criminal action (including fraud) or is otherwise in the overriding public interest.
5. How long will do we keep records for?
6. How we communicate with you about our similar products and services and information about your use of AFI and our partner websites
From time to time we would like to contact you about our products and services which we believe may be of interest to you.
There will be times when we will require your permission to provide information about our products and services. For example, when the information provided is not in relation to an enquiry made about our products or services.
We will not contact you unless you have opted to receive details in relation to the products and services we offer.
We may contact you without your permission if you fail to complete an online quotation, to see if we can offer you any help with this.
We may communicate with you by post, email, SMS, telephone and/or digital methods such as social media and online advertising, unless you have told us you do not want us to. You can ask us to stop contacting you about our products and services by:
• email at firstname.lastname@example.org
• post at No.1 The Crescent, Sun Rise Way, Solstice Park, Amesbury, SP4 7QA for the attention of the Data Protection Officer
• Call on 0344 557 0300
7. Access to your information and correction
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the address listed below.
We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct or remove information you think is inaccurate. Please contact us if this is the case.
Please note that in some cases even when you make a request concerning your personal information, we may not be required, or may not be able, to honour it as this may result in us not being able to fulfil our legal and regulatory obligations or there is a minimum statutory period of time for which we have to keep your information. If this is the case then we will let you know our reasons.
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.
However, please be aware that restricting or blocking cookies set on a website may impact the functionality or performance of the website, or prevent you from using certain services provided through the website. It will also affect our ability to update the website to cater for user preferences and improve performance.
Google Analytics is an industry-standard web analytics platform that provides us with statistical insight into website visitor behaviour and interaction, while Google AdWords provides (amongst other services) remarketing services to advertise to previous visitors to our site.
For example, you may see ads on Google or other websites, in the form of an advertisement on the Google search results page, or on a site in the Google Display Network, because we contract with Google and other similar companies to target our ads based on information we or they have collected.
You can opt-out of the Google Analytics Advertising Features we use by visiting Google’s ad settings page, configuring your relevant browser ads settings, or ad settings for mobile apps – please refer to your specific applications’ instructions or Help section for further information.
9. Other websites
11. How to contact us
• By email at email@example.com with the subject Data Protection Officer
• By post at No.1 The Crescent, Sun Rise Way, Solstice Park, Amesbury, SP4 7QA
• Call on 0344 557 0300
12. Your rights
Note: the following is to be used prior to 25 May 2018
You have a number of rights in relation to our use of your personal information including the right to:
• ask us to correct your personal information if it is wrong;
• object to processing of your personal information in certain circumstances;
• object to direct marketing.
You can make any of the request set out above at any time by using the contact details shown in your documentation. Please note in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can’t comply with your request, we will tell you why.
You have the right to:
• obtain a copy of the personal information we hold about you and certain details regarding how we use it. Please note that there will be a £10 charge for this. You can make a request by contacting the appropriate Data Protection Officer (see Contact Details of the Data Protection Officer in Section 5)
Note: the following is to be used from 25 May 2018 onwards
You have the following rights in relation to our use of your personal information.
The right to access your personal information:
You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible.
The right to rectification:
We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us by using the details shown in your documentation and you can ask us to update or amend it.
The right to erasure:
In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example according to the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.
Right to restriction of processing:
In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to process your personal information.
Right to data portability:
In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your personal information.
Right to object to direct marketing:
You have the right to object processing of you data in certain circumstances, this includes the right to object to direct marketing.
Right not to be subject to automated-decision making:
Some of our decisions are made automatically by inputting your personal information into a system or computer and the decision is calculated using certain automatic processes rather than our employees making those decisions. These Decisions involve the use of systems, such as our price rating, and are dependent on the information you provide us (for example: post code, the breed of your pet and its age)
You have a right not to be subject to automated decision-making in the circumstances described above and where automated decision-making used in the assessment of your application or fraud prevention, you can contact us to request that any declined decision is reconsidered. If you want to opt out of automatic decision-making, let us know, although in some circumstances it may mean we can’t offer you a quote or policy as some automated decisions are necessary to provide your insurance policy.
The right to withdraw consent:
For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Please note in some cases we may not be able to process your insurance if you withdraw your consent.
Right to lodge a complaint:
You have the right to be confident that we handle your personal information responsibly and in line with good practice.
If you have a concern about the way we are handling your information please let us know using the contact details listed above. If you would like more information about how to make a complaint to us please see our complaints page.
If you would like to contact the Information Commissioner’s Officer by email you can click on the following link https://ico.org.uk/global/contact-us/email/
You can write to the Information Commissioner’s Office at, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.