Effective Date: August 28th, 2025
battleface Inc, an Ohio Corporation, including subsidiaries, battleface Insurance Services LLC, battleface Insurance Services LTD UK, battleface Underwriting Services SRL and battleface Insurance Services SRL, battleface Insurance Services PTY LTD Australia and battleface Insurance Services Limited Canada (“we,” “our,” “us”) values your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, share, and protect your information when you interact with us through our websites, mobile applications, or other services (“Services”).
This Privacy Policy applies to all battleface users worldwide, including residents of the UK, EU, US, Australia, Canada and other international jurisdictions.
Changes to This Policy
We may update this policy periodically. Changes will be effective upon posting to our website with the updated “Effective Date.” Continued use of our services after updates indicates acceptance.
What Information We Collect
We collect personal information directly from you, automatically through your use of our services, and from third-parties.
Categories of Personal Information
- Identity Data: Name, date of birth, gender.
- Contact Data: Address, email, phone number.
- Policy and Claims Data: Insurance details, claims history.
- Financial Data: Payment card or bank account information.
- Technical Data: IP address, device ID, browser type, geolocation.
- Usage Data: Interactions with our websites and services.
- Marketing Preferences: Communication preferences.
- Sensitive Personal Information (SPI): Health details, biometric data, or other information required for specific services.
Sources of Information
- Directly from you: Applications, claims, surveys, and feedback.
- Automatically collected: Through cookies, pixels, and other tracking technologies.
- Third-parties: Insurance brokers, claims adjusters, analytics providers, public records.
How We Use Your Information
We process your information for the following purposes:
- Providing Services: Issuing policies, processing claims, and managing accounts.
- Marketing: Sending promotional offers with your explicit consent.
- Compliance: Meeting legal and regulatory obligations, including fraud prevention.
- Improvement: Enhancing website functionality and user experience.
- Security: Safeguarding data and preventing unauthorized access.
Cookies and Tracking Technologies
We use cookies, web beacons, and similar technologies to enhance your experience.
Types of Cookies
- Essential Cookies: Necessary for website functionality.
- Preference Cookies: Save your preferences for a tailored experience.
- Analytics Cookies: Collect usage data to improve our services.
- Advertising Cookies: Deliver targeted ads.
You can manage cookies through your browser settings. For more details, please see the regional Cookie Policy on our website.
Data Protection Laws
US Residents: In the United States, data privacy rights are primarily based on industry-specific legislation rather than a general data protection framework.
- California Residents: Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents may:
- Request access to personal information.
- Opt-out of data sales or sharing.
- Request deletion of personal data.
- To exercise these rights, click Do Not Sell My Personal Information or contact us directly.
- Residents of Other States
- Residents of Colorado, Connecticut, Utah, and Virginia may also exercise similar rights. Contact us for specific details.
- Children’s Privacy
In the US we comply with the Children’s Online Privacy Protection Act (COPPA) and do not knowingly collect data from children under thirteen without parental consent. For insurance applications involving minors, a parent or guardian must complete the process.
UK/EU Residents: battleface operates in compliance with the following data protection laws:
- The UK General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.
- The EU General Data Protection Regulation (GDPR) if you are within the European Economic Area (EEA).
- As per these regulations, battleface as the data controller, ensures that your personal data is processed lawfully, transparently, and for specified purposes.
Your Rights under the UK/EU GDPR:
You have the right to:
- Request access to your personal data.
- Request correction or deletion of your personal data.
- Object to processing.
- Request restriction of processing.
- Exercise the right to data portability.
Australian Residents: battleface complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) that govern the collection, use, and disclosure of personal data.
Your Rights under Australian Law (APPs): As an Australian resident, you have the right to:
- Access the personal data we hold about you.
- Request correction of your personal data if it is incorrect or outdated.
- Request deletion of your personal data, subject to legal or contractual restrictions.
- Complain to the Office of the Australian Information Commissioner (OAIC) if you believe that we have not handled your personal data in accordance with the APPs
Canadian Residents: battleface complies with the Personal Information Protections and Electronic Documents Act (PIPEDA), which protects personal information in the private sector.
- PIPEDA applies to private sector organizations that collect, use, and disclose personal information in the course of commercial activities. It sets out the rules for how organizations must handle personal data, ensuring individuals have rights regarding their information, including access and correction rights.
- PIPEDA is enforced by the Office of the Privacy Commissioner of Canada, which investigates complaints and ensures compliance with the law.
- In addition to federal laws, each province and territory in Canada has its own privacy legislation that may apply to the handling of personal information in the private sector. The following provinces have Privacy Laws that apply instead of PIPEDA:
- British Columbia Personal Information Protection Act (PIPA)
- Alberta’s Personal Information Protection Act
- Quebec Privacy Law
Specific Data Collection Practices
- For US Residents: We may collect health-related information if required for claims. The processing of health information is primarily governed by state and federal regulations such as HIPAA.
- For UK/EU Residents: We may collect Special Categories of Personal Data including health-related information, criminal convictions, or other sensitive personal data, in accordance with the UK GDPR or EU GDPR. This data will only be processed when absolutely necessary for the provision of services, and we will always seek explicit consent or rely on another lawful basis for processing.
- For Australian Residents: battleface may collect Sensitive Data as defined under the Privacy Act 1988, such as health information. This sensitive data will be processed in accordance with the APPs, and explicit consent will be obtained where necessary. If you do not wish to provide sensitive data, we may not be able to provide some services (such as medical assistance or claims processing).
Marketing Communications
- For US Residents: Under the CAN-SPAM Act, battleface will send marketing emails with your consent, and you may opt out at any time by clicking the unsubscribe link included in all marketing communications.
- For UK/EU Residents: battleface will send marketing communications only with your explicit consent. You can opt out marketing emails at any time by contacting us directly.
- For Australian Residents: battleface will send marketing communications with your consent, in compliance with the Spam Act 2003 (Cth). You can opt out of receiving marketing emails at any time by following the unsubscribe instructions included in the emails.
- For Canadian Residents: with your consent battleface will send marketing communicatons to you, in compliance with Canada’s Anti-Spam Legislation (CASL). You will be informed at the time of consent how your address will be used and how you may opt out of marketing emails at any time by following unsubscribe mechanisms included on the emails.
Sharing Your Information
We share personal information only as necessary:
- With Service Providers: For claims processing, IT support, and payment services.
- With Third-Party Marketers: Only with your explicit consent.
- For Legal Compliance: To meet regulatory obligations or protect our rights.
- During Corporate Transactions: In mergers, acquisitions, or sales of assets.
We do not sell your personal information for independent third-party marketing.
International Transfers of Data
- For US Residents: Personal data may be transferred to countries outside the United States, including to the EU. battleface ensures compliance with relevant US data privacy laws and frameworks.
- For UK/EU Residents: Personal data may be transferred to countries outside the EEA, such as the US or Canada. battleface ensures that such transfers comply with the applicable data protection laws by utilizing mechanisms such as Standard Contractual Clauses (SCCs) or other approved transfer mechanisms.
- For Australian Residents: Personal data may be transferred internationally, including to the US or the EU. battleface will ensure that such transfers comply with Australian privacy law by using approved contractual mechanisms or relying on specific exemptions under the Privacy Act 1988.
- For Canadian Residents: Personal data may be transferred internationally to organizations in other jurisdictions for processing. battleface will ensure such transfers comply with established rules under the Personal Information Protection and Electronic Document Act (PIPEDA).
Security and Retention of Personal Data
We implement technical and organizational measures to safeguard your data. While no system is completely secure, we take reasonable steps to protect your information.
We retain personal data only as long as necessary to fulfill its purpose, comply with legal obligations, or resolve disputes.
- For US Residents: Personal data retention is determined based on applicable US laws, such as state-specific data retention regulations, which may vary depending on the industry and jurisdiction.
- For UK/EU Residents: Personal data will be kept for no longer than necessary for the purposes it was collected for, as required under the UK and EU GDPR. Data retention periods are determined based on legal, regulatory, and contractual obligations.
- For Australian Residents: Personal data will be retained in accordance with the Australian Privacy Principles (APPs). We will retain your personal data only as long as necessary for the purposes for which it was collected, or as required by law.
- For Canadian Residents: Personal data will be retained in accordance with PIPEDA Fair Information Principle 5. Unless you consent otherwise, your personal information will be kept only as long as necessary for the purposes for which it was collected, or as required by law.
Your Privacy Rights
Depending on your location, you may have the following rights:
- Access: Request a copy of your personal information.
- Correction: Update inaccurate or incomplete information.
- Deletion: Request the deletion of certain data, subject to legal exceptions.
- Opt-Out: Decline marketing communications or data sharing for non-essential purposes.
- Data Portability: Receive your data in a structured format.
- Restrict Processing: Limit specific uses of your data.
Exercising Your Rights
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us by emailing us at [email protected] or writing to us. Please include your name, contact details, and specific request for verification purposes.
Contact Information:
US
battleface Inc. battleface Insurance Services LLC and Robin Assist LLC
Attn: Data Protection Officer
800 N. High Street
Columbus, OH 43215
UK Address:
battleface Insurance Servicer LTD
Attention: Data Protection Officer
Suite 102, 80 Churchill Square, Kings Hill
West Maling, Kent, ME19 4YU United Kingdom
EU Address:
battleface Underwriting Services SRL
Attention: Data Protection Officer
Avenue des Arts 6, 1210 Brussels Belgium
Australian/New Zealand Address
battleface Insurance Services PTY LTD
Attention: Privacy Officer
L11, 66 Clarence Street
Sydney, NSW 2000 Australia
Canada
Attention: Data Protection Officer
battleface Insurance Services Limited
199 Bay Street, Suite 4000
Toronto Ontario, Canada MSL 1A9
If you have questions or need assistance, contact us:
- Email: [email protected]