Effective Date: 09 September 2021
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, including if you wish to send us a request to exercise any of your legal rights, please contact us at firstname.lastname@example.org or +44 (20) 80895338 and your request will be passed on to our Data Protection Officer. You can also find out more information about how your personal data may be used by the insurance market in general in the Core Uses Information Notice.
Data Protection Officer
You may also contact our Data Protection Officer (DPO). The DPO has locations in the United Kingdom and in Belgium. If you want to raise a question to us, or otherwise exercise your rights in respect of your personal data, you may do so by contacting our Data Protection Officer by emailing: email@example.com or mailing your enquiry to the Data Protection Officer at the most convenient of the addresses set forth below:
battleface Insurance Services Limited
ATTN: Data Protection Officer
80 Churchill Square, Kings Hill
West Malling, Kent, ME19 4YU
battleface Underwriting Services SRL
ATTN: Data Protection Officer
Avenue des Arts 6
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, political opinions, trade union membership, 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 consented to provide us with this information, we will only use this to assess the availability of the cover 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 consent for us to process your health information, however, we may be unable to provide the services you have asked for without this information.
You may withdraw your consent at any time by emailing firstname.lastname@example.org however if you withdraw your consent this may result in us applying a restriction on your policy or in some instances, withdrawing your cover altogether.
We do not knowingly collect and personal data about children. If you are a parent or guardian and you are aware that your child has provided us with any personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.
Minimum Required Information
Where we need to collect personal data by law, or under the terms of a contract we have with you, 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. For example, if you have asked us to arrange a certain type of cover 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 (for example, the Electoral Register) and other third-party data providers. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioural 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 based outside the EU). 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 all the ways we intend to use any personal data, and which of the legal bases we intend to rely on in order to do so. We have also identified what our legitimate interests are where appropriate. You can obtain further information about how we assess our legitimate interests against any potential impact on you in relation to specific activities by contacting us. 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, 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. We use information for these purposes with your consent, to fulfil our agreement with you, to protect your vital interests, and because it is needed for own legitimate interests.
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 which are similar to those you have already purchased from us previously. This is necessary in order to keep you updated about products and services you have purchased, develop our range of products and services and grow our business. We use information for these purposes with your consent, and because it is needed for own legitimate interests.
If we have obtained your express opt-in consent, 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 tick if you wish to receive any such marketing materials. You have the right to withdraw your consent to receiving direct marketing at any time by contacting us. We use information for these purposes with your consent, and because it is needed for own legitimate interests.
Canada’s Anti-Spam Law requires that we obtain the express consent of Canadian citizens before sending an electronic message such as an email that contains a promotion about our products. We will ask you for your explicit consent when you provide us with your email address or other personal information through which we intend to encourage your participation in a commercial activity, such as a promotion for our products.
If you explicitly consent to receiving CEM, each communication sent to you will contain an option to unsubscribe to the communications or to revoke your consent to receive CEM. Alternatively, you can contact us at the address or email provided below in the “Contact Us” section to be removed from our mailing lists.
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 the most effective manner for you and for your computer, and as part of our efforts to keep our site safe and secure. This is necessary for the running of our business, provision of administration and IT services, network security and prevention of fraud. We may also need to use your information in the context of a business reorganisation 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 defence of any legal claims. We use information for these purposes to comply with our legal obligations because it is needed for own legitimate interests
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another lawful reason and that reason is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 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 respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We shall not share your personal data with any third parties for marketing purposes without your express consent. We shall however, share your personal data with third parties, for the following reasons:
We will share your personal data with service providers where this is necessary in order 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, regulators, phone system providers, hosting services, suppliers and sub-contractors. We may also need to 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, reorganisation, or acquisition
We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
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 organisations for the purposes of fraud protection, crime prevention, and credit risk reduction. We may also need to share information with Revenue & Customs authorities, regulators and other authorities acting as processors, who require reporting of processing 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 based who provide consultancy, 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 country of your residence so their processing of your personal data will involve a transfer of data to another country. If you reside in the UK, the EEA or other country with heightened privacy protections, this means that we may transfer data outside of your home country or region. Whenever we transfer your personal data across borders, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- If you reside in the UK and or EEA:
- We may transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the United Kingdom Secretary of State for Digital, Culture, Media and Sport, depending on where you reside. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain Service Providers, we may use specific contracts approved by the European Commission which give personal data a similar level of that it receives in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- We may enter into an agreement with the recipient incorporating standard data protection clauses (SCCs) recognised or issued in accordance with the EU and UK data protection regime.
- If you reside outside of the UK and/or the EEA, we will comply with all applicable laws regarding the transfer of your personal data to a third country.
“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 servers provided by Esecure, Coquitlam, B.C. Canada. 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 to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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 shall 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 shall use effective safeguarding procedures and security features to try to prevent any unauthorised access to your personal data.
HOW LONG WILL WE KEEP HOLD OF YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Where you have given us your permission to contact you for marketing purposes, we shall contact you regularly to ensure that you still wish to be contacted in this way.
Under certain circumstances, you have the following rights:
- to request that we provide you with a copy of the personal data that we hold about you (“Access Request”);
- to request that we rectify any personal data that we hold about you (“Right to Rectification”);
- to request that we erase any personal data that we hold about you (“Right to be Forgotten”);
- to restrict the level of processing we carry out with your personal data (“Restriction of Processing”);
- to obtain from us all personal data that we hold about you in a structured, machine readable form, and have this information transmitted to another organisation (“Data Portability”);
- to object to our processing your personal data in certain ways (“Right to Object”); and
- to withdraw your consent at any time to our processing of your personal data.
Please see the relevant sections below for further details on your rights as a data subject. You can exercise any of the above rights by contacting us as specified in the Contact section. Please note that we may ask you to verify your identity before responding to such requests.
We shall comply with any actionable request made under this section as soon as possible, and normally within one month from the date of your request. However, if necessary, for example if your request is particularly complex or we receive a number of similar requests, we may extend this period by an additional two months, but we shall notify you if we need to do this.
You also have the right to lodge a complaint with the UK Information Commissioner’s Office, or if you are resident of the EEA, the Autorité de Protection des Données if you are unhappy in any way with how we have treated your personal information. We would, however, appreciate the chance to deal with your concerns before you approach local data protection authority, so please contact us in the first instance.
You will not usually have to pay a fee to access your personal data (or to exercise any of your other rights). However, please note that where we receive requests under this section which are manifestly unfounded or excessive, for example because they are repetitive in nature, we may charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested or refuse to act on the request.
You have the right to request a copy of the information that we hold about you at any time. This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it. Please note that in most circumstances, we shall not make a charge for this. However, we may charge a reasonable fee based on administrative costs for any further copies requested.
Right to Rectification
You are required to ensure that the data we hold about you is kept up-to-date. You can update your personal data directly within your account settings section. If you are unable to make any required changed, please contact us by emailing email@example.com to make the required changes.
In any event. you have the right at any time to ask us to rectify any personal data that we hold for you which is incorrect or incomplete. This enables you to have corrected any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data that you provide to us. If we have disclosed any incorrect or incomplete data to any third parties, we shall inform them of any necessary amendments or corrections made to your personal data under this section.
Right to Be Forgotten
You have the right to ask us to erase the personal data that we hold about you in circumstances where:
- it is no longer necessary for us to handle your personal data for the purpose for which it was originally collected;
- you have withdrawn your permission for us to hold your personal data (where this was the basis on which it was collected or used);
- you object to the processing of the data and there is no lawful overriding reason for us to continue processing your personal data;
- the personal data was unlawfully processed; or
- we have to erase your personal data in order to comply with a legal obligation.
Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Restriction of Processing
You can ask us to restrict how we use your data in the following circumstances:
- where you believe that the information we hold about you is inaccurate, you can ask that we refrain from using your data until we can verify the accuracy of it;
- where we have unlawfully processed your data, you can ask that we restrict our usage of it rather than erase it completely;
- where we no longer need to hold your information, but you wish us to retain your information for the purpose of establishing, exercising or defending a legal claim; or
- where you have objected to our use of your information, but we need to verify whether we have overriding legitimate grounds to use it.
You have the right to obtain from us all personal data which you have provided to us in a structured, commonly used and machine-readable form, provided that such data was processed based on your consent, or for the purpose of a contract between us and the processing was carried out by automated means. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
This will allow you to move, copy or transfer personal data easily from one IT environment to another. Alternatively, we can transmit such data directly to another organisation. Please note that we shall not be able to comply with a data portability request if this will affect the rights and freedoms of others.
Right To Object
You have the right to object, on grounds relating to your particular situation, to our processing of your personal data where we are doing this for the performance of a task carried out in the public interest (which we shall have told you about, if applicable), or where we are carrying out processing for the purposes of legitimate interests pursued by us.
You also have the right at any time to ask us not to process your personal data for direct marketing or profiling purposes (to the extent that such profiling is related to such direct marketing). We shall have informed you before the time we obtained your personal data whether we intend to process your personal data for this purpose, or if we intend to disclose your information to any third party for such purposes.
If we process your personal data for automatic decision making or profiling purposes (e.g. to analyse or predict your personal preferences and purchase behaviour, and such profiling is automated) we shall tell you about this beforehand, and will only do this where this is a necessary condition of entering into a contract between you and us, or where you have given us your explicit consent to do this.
Right To Withdraw Consent
Where you have given us your consent to our processing of any of your personal data, you have the right to withdraw your consent at any time, for example if you no longer wish us to share your information with third parties for marketing purposes (where you have previously consented to this). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
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 where they are to be covered under the same Policy as a parent or guardian or a legally responsible adult); and 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 as soon as possible.