We take your privacy very seriously. Please read this Privacy Notice carefully as it contains information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event that you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as “controller” of that personal information for the purposes of those laws.
Who are we?
When we refer to “we” “us” and “our” in this notice it means The Equine and Livestock Insurance Company Limited, its trading names and Appointed Representatives as shown in as shown below:
The Equine and Livestock Insurance Company Limited
- The Insurance Emporium
- Breeder Choice
- Dove Pet Care
- National Pet Register
Entertainment & Leisure Insurance Services (Appointed Representative)
Entertainment & Leisure Insurance Services Ltd (Appointed Representative)
Entertainment and Leisure Insurance Services (Jersey) Ltd (Appointed Representative)
Lifestyle Policy Ltd (Appointed Representative)
We are joint controllers of your personal information. For details as to the joint controller arrangement in place between the parties, please contact us using the details set out in the "How to contact us" section below.
When we say “you” and “your” in this notice, we mean anyone whose personal information we may collect, including:
- anyone seeking an insurance quote from us or whose details are provided during the quotation process
- policyholders and anyone named on or covered by the policy
- anyone who may benefit from or be directly involved in the policy or a claim, including claimants and witnesses
What is personal information?
It is any information relating to an identified or identifiable individual.
What personal information do we collect?
We may collect the following types of personal information from you, your representative or from information you have made public, for example social media:
- your name and contact information, including email address and telephone number
- information to enable us to check and verify your identity, e.g. your date of birth, portal password
- your financial details such as direct debit or payment card information
- details of any other insurance you hold if it is relevant to your claim
- photographs and/or video to help us assess your claim
- your claim history
- your medical information if it is relevant to your policy or claim
- your criminal convictions if it is relevant to your policy or claim
- your accessibility details if we need to make reasonable adjustments to help
- your business activities if it is relevant to your policy or claim
This personal information is requested to provide products and services to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing products and services to you.
How do we collect your personal information?
We collect most of this personal information directly from you – in person, by telephone or email and via our website and customer portal. However, we may also collect information from:
- publicly accessible sources e.g. Companies House or HM Land Registry
- veterinary and/or referral practices, charities and breeders
- any other insurer with whom you have relevant insurance
- emergency services, law enforcement agencies, medical and legal practices
- brokers and affiliates
- suppliers of repair or replacement estimates
- loss adjusters and our consultant veterinary advisors
- other involved parties, for example, claimants or witnesses
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations ("Compliance with Law")
- for the performance of our contract with you or to take steps at your request before entering into a contract ("Performance of a Contract")
- for our legitimate interests or those of a third party ("Legitimate Interests")
- where you have given consent ("Consent")
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide quotes, administer policies and claims||Lawful basis: Performance of a Contract|
|To prevent and detect fraud against you or us||Lawful bases: Compliance with Law or Legitimate Interests (to protect You or Us from fraud)|
|Processing necessary to comply with professional, legal and regulatory obligations that apply to our business||Lawful basis: Compliance with Law|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||Lawful bases: Compliance with Law or Legitimate Interests (to cooperate with regulators)|
|Ensuring business policies are adhered to e.g. policies covering security and internet use||Lawful basis: Legitimate Interests (to comply with our policies)|
|Ensuring the confidentiality of commercially sensitive information||Lawful basis: legitimate Interests (to maintain confidentiality of sensitive information)|
|Statistical analysis to help us manage our business e.g. in relation to our financial performance, customer base, product range or other efficiency measure||Lawful basis: Legitimate Interests (to operate our business in a more efficient manner)|
|Preventing unauthorised access and modifications to systems||Lawful bases: Compliance with Law and Legitimate Interests (to protect the integrity of our systems)|
|Updating and enhancing customer records||Lawful basis: Legitimate Interests (to operate our business properly)|
|Statutory returns||Lawful basis: Compliance with Law|
|Marketing our services and those of selected third parties to:
- existing and former customers
- third parties who have previously expressed interest in our products
- third parties with whom we have no previous dealings
|Lawful bases: Consent or Legitimate Interests (to develop and grow our business)|
|External audits and quality checks and the audit of our account||Lawful bases: Compliance with Law or Legitimate interests (to ensure that our business is being run in an appropriate manner|
We may use your personal information to send you updates (by email, text message, telephone or post) about our products, including exclusive offers, promotions and new products.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send your promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it to other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at [email protected]
- using the “unsubscribe” link in emails
- write to us at the address shown in “How to contact us” below
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products in the future, or if there are changes in the law, regulation or the structure of our business.
Who do we share your personal information with?
We may share your personal information with:
- third parties we use to help deliver our products and services to you e.g. payment service providers, repairers, veterinary advisors, legal advisors and loss adjusters
- other third parties we use to help us run our business, e.g. marketing agencies, website hosts, online review platforms
- third parties approved by you e.g. social media sites you choose to link your account to or third party payment providers
- Insurance Fraud Bureau
- other insurers, reinsurers, insurance intermediaries, regulators, law enforcement and the Financial Ombudsman Service (FOS) and other companies that provide services to us or you
We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We may also share personal information with external auditors, e.g. in relation to accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where do we hold your personal information?
Information may be held at our offices, third party agencies and service providers (see above: “Who do we share your personal information with?”)
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Will we transfer your personal information out of the EEA?”
How long do we keep your personal information?
We will keep your personal information for as long as we need it to administer your policy or manage our business. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf
- to show that we treated you fairly
- to keep records required by law
We will not retain your personal information for longer than necessary for the purposes set out in this notice.
Will we transfer your personal information out of the EEA?
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA). These transfers are subject to special rules under European and UK data protection law. Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. Where personal information is transferred to and stored in a country not determined by the UK or the European Commission as providing adequate steps of protection for personal information, we take steps to provide appropriate safeguards to protect your personal information, including entering into standard contractual clauses approved by the UK or the European Commission, obliging recipients to protect your personal information.
If you would like further information on the specific mechanism used by us when transferring your personal information outside of the UK or the EEA, please contact us using the details set out in the "How to contact us" section below.
What are your rights?
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information – in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information – in certain circumstances e.g. if you contest the accuracy of the data|
|Data portability||The right to receive personal information you provided to us, in a structured, commonly used and machine readable format and/or transmit that data to a third party – in certain situations|
|To object||The right to object:
- at any time to your personal information being processed for direct marketing
- in certain other situations to our continued processing of your personal information e.g. processing carried out for the purpose of our legitimate interests
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- request and complete a Data Subject Access Request form; or
- email, call or write to us — see below: “How to contact us”; and
- let us have enough information to identify you (e.g. your full name, address and policy number); and
- let us have proof of your identity and address (a certified copy of your driving licence or passport and a recent utility bill); and
- let us know what right you want to exercise and the information to which your request relates.
How do we keep your personal information secure?
We have appropriate security measures to prevent information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
What if I believe my personal information has been mishandled?
We encourage you to contact us in the first instance - see below: “How to contact us” but you are entitled to go directly to the Information Commissioner’s Office (ICO) at www.ico.org.uk or telephone 0303 123 1113.
How to contact us
Please contact us by post, email or telephone if you have any questions about this notice or the information we hold about you.
Changes to our Privacy Notice
We may change this notice from time to time; the most recent version will always be available on our website.
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