Effective Date 23 August 2021
This Policy sets out the basis on which we collect personal data (as defined below) from you and the way in which it will be processed by us. Please read this Policy carefully to understand our practices regarding your personal data and how we shall treat it. We are committed to protecting and respecting your privacy.
It is important that you read this Policy together with any other privacy notice or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Policy supplements any other such notices and is not intended to override them.
If you have any questions about this Policy, please contact us at:
battleface Insurance Services LLC
629 N. High Street 6th Floor
Columbus, OH 43215
CHANGES TO THIS POLICY
We may update this Policy from time to time. We will notify you of any changes by posting the updated Policy on this page or by sending you an email where this is how we usually communicate with you. You are advised to review this page periodically for any changes. Changes to this Policy are effective when they are posted on this page.
TYPES OF PERSONAL DATA WE COLLECT
“Personal data” means any information which identifies (or from which we can identify) a natural person. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- “Identity Data”, which comprises your first name, middle name, last name, age and date of birth.
- “Contact Data”, which comprises your address, email address and telephone number(s).
- “Technical Data”, which comprises your IP address, browser type and version, time zone setting and location, geolocation, browser plug-in types and versions, operating system and platform and other technology on the device(s) you use to access our website.
- “Usage Data”, which comprises information about how you use our website, products and services.
- “Profile Data”, which comprises your username and password, insurance policy and claims details.
- “Marketing and Communications Data”, which comprises your preferences in receiving marketing from us and third parties, your communication preferences, and recordings of telephone conversations we have from time to time.
- “Transaction Data”, which comprises information enabling us to provide products and services, travel plans, age categories of individuals to be insured, information about your trip and any your policy such as the destination, insurance rating and policy, payment card information, and information about any insurance claims you make, including bank information required to process loss payments, and health information required to pay health expenses.
We also collect, use and share “Aggregated Data” such as statistical or demographic data. Aggregated Data may be derived from your information but does not constitute “personal data” in law as it does not directly or indirectly reveal your identity. For example, we may aggregate (i.e. combine with information relating to others) your Usage Data to calculate the percentage of users accessing a specific feature of our website. However, if we combine or connect Aggregated Data with your information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be handled in accordance with this Policy.
Special Categories of Personal Data
“Special Categories” of personal data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, information about your health and genetic and biometric data. This also, for the purposes of this Policy, includes information about criminal convictions and offences.
We may need to collect certain Special Categories of Personal Data about you in order to provide you with the services you have requested, such as any pre-existing medical or other health condition. If you have provided us with this information, we will only use it for the purposes for which it was collected, e.g., to assess the availability of the insurance you have requested and where necessary to provide you with the benefits under the Policy in the event of a claim. You are not under any obligation to provide us your health information, but we may not be able to provide the services you have asked for without this information.
You may request that we not use Special Categories information at any time by emailing email@example.com. If you do so, however, this may result in us applying a restriction on your policy or, in some instances, withdrawing your coverage altogether.
battleface Insurance Services LLC accepts applications for minor children with the condition that a parent or legal guardian completes and signs the application. We do not knowingly collect personal data about children except with parental consent. If you are a parent or guardian and you are aware that your child has provided us with personal data without your consent, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we will take steps to remove that information from our active servers. Minimum Required Information
Where we need to collect personal data by law, under the terms of a contract we have with you, or as required by our operations or internal policies, and you fail to provide the minimum required data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the product or service you have purchased). In that event, we may have to cancel our agreement with you to provide a product or service you have requested and will notify you if this is the case at the time or as soon as reasonably possible. For example, if you have asked us to arrange a certain type of coverage for you, we may ask for further details in order to assess your application and complete our identity, money laundering and credit checks before we are able to do so.
WHEN DO WE COLLECT PERSONAL DATA?
We may collect information on you in the following ways:
Information that you voluntarily provide to us
When you request a product or service from us, consult with our customer service team, send us an email, request a brochure, fill in forms on our website, enter a competition, promotion or survey, or communicate with us in any way, you are voluntarily giving us information that we collect. We also collect information you give to us when we contact you during the course of entering into a contract with you or in the process or managing your customer account. That information may include your Identity Data, Contact Data, Transaction Data, Technical Data, Profile Data and Marketing and Communications Data.
Information that we collect automatically
Information from other sources
From time to time we may obtain information about you from third party sources such as public databases and other third-party data providers. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links) from analytics providers and search engine providers (for example, Google). We use this information, alone or in combination with other information (including personal data) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.
WHY WE COLLECT YOUR PERSONAL DATA AND HOW WE USE IT
We have set out below a description of ways we intend to use any personal data. We may use and disclose your personal information for the following purposes:
Entering into an agreement with you and provide our services
In providing you with our products or services, we will use your Identity Data, Contact Data, Transaction Data, Technical Data, Profile Data and Marketing and Communications Data. We will also use this information to process your insurance application, to process any payments, to manage your customer account, to keep adequate records of your past purchases, and to contact you regarding our agreement with you, including providing customer support and detecting, preventing and addressing technical issues. We may also collect information to facilitate the delivery of assistance services, including medical information to manage emergency situations.
To manage our relationship with you
We may send you important updates about changes to the way in which our products or services work. We may also invite you to provide feedback on our products and services whether by email or by telephone. We may also, unless you have opted-out, send you information electronically about our own products or services. We do this to keep you updated about products and services you have purchased, develop our range of products and services and grow our business.
We may send you, or permit selected third parties to send you, other forms of marketing, for example regarding other products and services. We shall make sure it is clear when you are able to give us permission to do this, for example, we have an online form and boxes that you need to check if you wish to receive any such marketing materials. You may discontinue direct marketing at any time by contacting us.
To administer and protect our business and this website
We may also use your information in order to protect our business and our website, and to help us monitor or improve the products or services that we offer. This includes troubleshooting, statistical and data analysis, testing, system maintenance, support, reporting and hosting of data. We also use your information to improve our website so that content is presented in a more effective manner for you and for your computer, and as part of our efforts to keep our site safe and secure. We use this for the running of our business, provision of administration and IT services, network security and prevention of fraud. We may also use your information in the context of a business reorganization or group restructuring exercise. Please note that we record telephone conversations for training and monitoring purposes and that we may also use this information in the event of any legal or regulatory matter, such as in the event of the exercise or defense of any legal claims.
We may use your personal data for purposes beyond those listed above or for which we collected it if we reasonably consider that we need to use it for another lawful reason. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
WHEN WILL WE SHARE YOUR PERSONAL DATA?
We require all third parties to whom we provide your personal data to respect the security of your personal data and to treat it in accordance with the law. We may share your personal data with third parties for the following reasons:
We will share your personal data with service providers to provide you with products or services that you have requested. Examples of Service Providers include insurers, agents or brokers, reinsurers, loss adjusters, sub-contractors, phone system providers, hosting services, suppliers and sub-contractors. We may also share your personal data with third party software or IT support providers from time to time for the purpose of system administration, data security, data storage, back up, disaster recovery or IT support.
Advertising partners and remarketing services
To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition
To comply with law and to protect the rights, property, or safety of our business and other clients
We reserve the right to disclose or share your personal data in order to comply with any legal or regulatory requirements, enforce our terms and conditions (or any other agreement we enter into with you), or to protect the rights, property, or safety of our business and other clients. This includes exchanging information with other companies and organizations for the purposes of fraud protection, crime prevention, and credit risk reduction. We may also need to share information with tax authorities, regulators and other governmental authorities who require reporting of activities in certain circumstances, including for example law enforcement agencies, detection agencies and compulsory insurance databases. We may also share your personal data with our professional advisers including lawyers, bankers, auditors and insurers who provide services such as consulting, banking, legal, insurance and accounting services.
Third Party Websites
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website that you visit.
Some of our external third parties may from time to time be based outside of the United States so their processing of your personal data will involve a transfer of data outside the United States. When you provide us with personal data or otherwise use our site, apps, or services, you consent to this transfer.
“Do Not Track” Signals
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
WHERE WILL WE STORE YOUR PERSONAL DATA?
All personal data that you provide to us is stored on secure third party servers. We use appropriate measures to ensure that your data is treated securely and in accordance with this Policy and comply with the relevant data protection legislation.
We have put in place appropriate security measures aimed at reducing the risk of your personal data being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please note that the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we use safeguarding procedures and security features to try to prevent any unauthorized access to your personal data.
INFORMATION FOR CALIFORNIA RESIDENTS
California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. We do not share Personal Information with third parties for their own marketing purposes, however. California customers may request further information about our compliance with this law by e-mailing us at the address listed in the “Contact Us” section.
The above rights are separate from rights that California residents may have under the California Consumer Privacy Act (“CCPA”). Note that the Company is not subject to the CCPA as a “business” (as defined in the statute). Nonetheless, we respect the privacy and wishes of individuals regarding their privacy. As such, you may make a request regarding our use, handling and protection of your Personal Information by contacting us.
Our websites, apps, and services are not intended for use by children. We do not intentionally gather personal data from individuals who are under the age of 13 except with the consent of a parent or guardian. We do accept insurance applications for minor children with the condition that a parent or legal guardian completes and signs the application. If a child has provided us with personal data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13 without consent, please contact us at firstname.lastname@example.org. If we learn that we have inadvertently collected the personal data of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information from our active servers as soon as possible.