Animal Friends is committed to ensuring the privacy and security of our data. We are registered as a data controller with the Information Commissioner’s Office (registration no. Z6313845).
How We Process Personal Data
Animal Friends takes the security and privacy of your information seriously. We are ISO27001 certified. All information is held in the UK, unless otherwise specified. We will never share your information with third parties without your consent unless there is a legal reason to do so.
When you purchase a pet insurance policy from Animal Friends, we retain such information as is necessary to provide you with that insurance product. That is, your name, contact details, and relevant information about your pet such as their breed, age, and any pre-existing conditions. We also ask for your pet’s microchip number. We collect payment information at the point of purchase through a secure line. If you set up a direct debit, we will hold your sort code and account number for as long as that direct debit is active to allow us to take continuous payments.
We may ask you to undertake fraud prevention checks at the point of sale. For example, a credit referencing check through a third party such as Experian. Credit referencing agencies are multinational and may hold data outside of the EEA in countries without Adequacy status. We conduct rigorous security checks of all partner organisations and have Standard Contractual Clauses in place. We also periodically check our back book through fraud prevention and credit referencing agencies to manage risk and prevent criminal activity.
If you submit a claim, we will ask for information about your pet’s condition and the treatment they received. We may ask for receipts and treatment plan documentation. We may need a medical history for your pet to confirm that any condition is not pre-existing. We may talk directly to your vet to get further information where necessary. This information is used to assess claims in line with the terms and conditions of your insurance contract.
To comply with FCA requirements we retain full details of all complaints. Where you complain on social media or on a review website, whether privately or publicly, please be aware that we may be required to treat this under our complaints process in line with FCA requirements. If we can match a complaint made on social media or on a review website to a customer record based on information provided in that complaint, or which is publicly and obviously available on the site where you have complained, we may do so in order to provide a more personalised response.
Those claims which can be easily settled and paid in full without the customer providing any further information, for example which have already been approved in relation to treatment or medication for ongoing conditions, may be processed by automated means. Customers can query the outcome of a claim and have it reviewed by a dedicated claims handler at any time by contacting Customer Services.
Where we have reason to believe a claim may be fraudulent or criminal activity has occurred, we may share relevant information with other insurance companies, fraud prevention and credit referencing agencies, and law enforcement as necessary. Where another insurance company or an authorised agency requests information in relation to fraud or criminal activity, we may provide that information. We retain fraud investigation files for up to 10 years to mitigate risk internally.
Where you indicate that you require reasonable adjustments or personalised support, for example if you have a language barrier or medical condition, we will ask for your explicit consent to record this on your customer file. Such sensitive information will only ever be used to provide you with the support you have requested.
If you contact Customer Services, they will note the content of that call in your file. We also retain call recordings for two years. We operate Customer Service teams in the UK and India. All customer data where Animal Friends is the responsible party is held in the UK and access internationally by our team in India is via a secure and continuously monitored portal.
Where you add an authorised person to your account, that is a person who may act on your behalf or who is also party to the insurance contract, please be aware that they may have access to all information you provide to us. An authorised person may also cancel a policy on your behalf, transfer the policy to another party, or change the details. Adding an authorised person requires your consent.
We require the consent of the policyholder (or an authorised person), proof of death, or proof that the policyholder is otherwise incapacitated to transfer a policy to the ownership of another party. We call this a “transfer of interest”. A transfer of interest may change your pricing or terms and conditions. While we do try to accommodate our customers, we cannot guarantee that we will be able to make a transfer of interest.
We retain full customer records for 6 years after the termination of the contract, in line with HMRC requirements regarding financial records and to facilitate the provision of insurance services. Call recordings, not forming part of the financial record, are held for 2 years for audit purposes.
Animal Friends Insurance products can only be purchased by persons over the age of 18 and we will never knowingly collect children’s data. Exceptions to this are for the provision of a ‘Young Rider’ policy or in relation to a public liability claim. In such instances, we will seek the consent of the young person’s parent or Legal Guardian to process data relating to persons under the age of 13.
Animal Friends operates Chatbot to provide an auto-answer and Live Chat service. It may also connect customers and website users to our Customer Services team upon request.
Chatbot uses technology provided by Google and Google holds this data in the US, which does not enjoy the same privacy rights as the UK. While Google does have Standard Contractual Clauses in place, as required for international data transfers, these may not be enforceable given the differences between US and UK law. We will remind you of this and ask for your consent before we collect any information on Chatbot. The only information collected by Chatbot is your name, postcode, and pet’s name. We use this information to locate your account more quickly, prior to transferring you to a Live Chat agent. We do not further retain these communications.
Chatbot also provides a Live Chat service. Live Chat information is retained in customer records (where relevant to a customer), or otherwise automatically deleted after two years. Customer support information, such as Live Chat records, are retained for the purposes of the provision of insurance services. They also help us to comply with legal and regulatory requirements, such as relating to financial records for HMRC and FCA obligations.
Animal Friends conducts marketing and promotional activities on a consent basis. You can opt into marketing during your quote journey, by contacting Customer Services, or on our website. You can opt-out by clicking the link in any marketing or promotional communication, by emailing our marketing team directly at email@example.com or by contacting Customer Services. If you notify us that your pet has passed away, we will automatically remove you from our opt-in lists for all marketing and promotional communications.
We utilise an email tracking service to ensure renewal and contract information is received and to understand whether marketing emails are opened by the recipient. Where the tracking service indicates that marketing emails have gone to spam or junk mail folders, we will remove the recipient from our opt-in to marketing lists.
When you opt into marketing, Animal Friends will retain your name and contact details specific to the type of marketing you have opted in to (for example, if you opt in to receive email marketing communications, we will only retain your email address for this purpose). We will also retain information about your pet from your policy, such as the pet type, age, and breed, to allow us to personalise those communications.
Where you enter a competition, unless you indicate that you wish to receive marketing communications, we will only process such information as required to facilitate that competition entry.
We may use your name, contact information and postcode, combined with pet information including the type, breed, age, and any conditions, to include or exclude customers from targeted advertising on social media. This activity is conducted under the lawful base of legitimate interests and is subject to a fairness and legitimacy test. You may opt-out of this activity at any time by contacting Customer Services or emailing our Marketing team at firstname.lastname@example.org.
Where Animal Friends engages in partnerships with other organisations, such as Joii or Biscuit, they act as joint controllers. That means, you can find transparency information on the website of those partner organisations. We may share some information about customers or users between ourselves to facilitate that partnership or service. This information will be available on the website of the applicable partner organisation.
We retain information for the minimum time possible for the purpose for which it is processed. This period will be different depending on the type of personal information. For example, we retain full customer records for 6 years after the termination of the contract. This period has been determined based on the HMRC requirement to retain records of financial transactions and associated evidence for a minimum of 6 years. We retain call recordings for 2 years for audit purposes. Quotes which did not progress into a sale are retained for 90 days to allow the individual to return to the quote within a reasonable period if necessary.
If you require further information about our retention periods, please contact our Data Protection team.
We always aim to process personal data in the UK where possible, as we feel this gives the individual the most control of their data and provides greater security. However, where that is not possible, we will always seek a processing location in the EEA or a country with Adequacy status.
We do use Google, based in the US, for Analytics cookies on our website and to provide our Chatbot and Live Chat services. We do so with Standard Contractual Clauses in place, while offering individuals a way to opt-out or utilise a different service method.
We also operate a customer service and claims handling service in India. However, all data in that case is stored in the UK. It is accessed by staff in India with extremely restrictive security controls and live monitored from the UK.
Where we work with third parties which may be multinational or based outside of the EEA in countries without Adequacy status, such as for fraud prevention and credit referencing services, we do so with Standard Contractual Clauses in place and do our best to offer an opt-out or consent option for the customer. We undertake rigorous security checks of all third parties with whom we work.
Animal Friends is ISO 27001 accredited. We take the security of information seriously. For more information about specific security controls, please contact our Data Protection team.
Your Data Protection Rights
If you wish to exercise any of your rights, for example make a subject access request or request erasure or your data, please contact our Data Protection team directly.
You have a number of important rights under data protection law as regards your personal data.
Your right of access - You have the right to ask us for a copy of your personal information. You have the right to ask for more information about how your information has been collected, used, stored, shared, or otherwise processed.
Your right to rectification - You have the right to ask us to correct any personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. Please note, we cannot erase any information which is processed for the purposes of compliance with a legal or regulatory requirement, or which is required to facilitate your insurance product.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to provide a final response.
If you have any concerns about our use of your personal information, you should contact our Data Protection team. Any concerns, queries, or complaints in relation to the handling of personal data will be referred internally to the Data Protection team.
You can also complain to the ICO if you are unhappy with how we have processed your data.
Information Commissioner’s Office