Privacy and Security
Protecting your personal information is extremely important to Bobatoo. It’s especially important for our customers to trust us to look after a huge amount of sensitive information on everything from their personal details to their medical history.
The way we collect and share your information is equally important. Our customers expect us to manage their information privately and securely. If we don’t, they’ll lose their trust in us. This policy tells you how we collect and process your personal information. Please take a few minutes to read it, and show it to anyone else connected to us.
What does this policy cover?
What is personal information?
When we talk about personal information we mean information about an individual that can identify them, like their name, address, e-mail address, telephone number and financial details. It can relate to customers, employees, shareholders, business contacts and suppliers. Any reference to “information” or “data” in this policy is a reference to personal information about a living individual.
What information do we hold?
We may collect and process the following personal information about you:
|TYPE OF DATA||DESCRIPTION||EXAMPLES OF HOW WE USE IT|
|Contact||Who you are
Where you live
How to contact you
|Servicing your product
Analysis & profiling
Enhancing our product and service offering
Visual images & personal appearance
Lifestyle and social circumstances
Analysis & profiling
|Transactional||Bank and/or card details
How you use your product
Changes you make to your product or account
|Servicing your policy
Making sure our products and services are fit for purpose
|Contractual||Your application||Making sure the policy is right for you|
|Consent & preferences||Ways you want us to market to you||Marketing|
|Technical||Details on the devices and technology you use||Making sure our products and services are fit for purpose|
|Open data & public records||Electoral register
Other information about you that is openly available on the internet
|Documentary data & national identifiers||Details about you that are stored in documents like:
National Insurance number
|Prevent financial crime|
Where do we get our information from?
Information you give us directly (when you fill in forms or contact us by phone, e-mail etc.).
How do we use your information?
We use personal information that we hold about you:
- To carry out our responsibilities resulting from any agreements you’ve entered into with us or our business partners (e.g. to underwrite and administer your policy) and to provide you with the information, products and services that you’ve asked from us.
- To provide you with marketing information about services and products we offer across the Bobatoo group which may be of interest to you. Based on your marketing preferences, we may deliver this information by post, telephone, e-mail, SMS. We may also send marketing to you using our “legitimate interests”, please see below for further information.
- To tell you about changes to our services and products.
- To comply with any applicable Bobatoo requirements
- For carrying out market research, statistical analysis and customer profiling to help us to improve our processes, products and services and generate new business (e.g. to understand digital behaviours, identify financial attitudes and develop more engaging communications).
- To define our actuarial, pricing strategies.
- To run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit.
- For any other purpose that we’ve agreed with you from time to time.
When you apply for a product or to receive a service from us, the application form you fill out or the resulting contract may contain additional conditions relating to the way we use and process your personal information. These will apply in addition to the above uses.
In some cases, we may use systems to make automated decisions (including profiling) based on the personal information we have, or collect from others. These may include:
- The prevention and detection of fraud.
- Providing quotes, calculating premiums and underwriting decisions.
- Personalising the content and design of communications and online services
- Determining when to provide tailored servicing communications (e.g. changes in your personal circumstances or lifestyle), and the appropriate channel(s) to use.
Using your information in accordance with data protection laws
- Providing our services to you: We’ll process your personal information to carry out our responsibilities resulting from any agreements you’ve entered into with our business partners on your behalf and to provide you with the information, products and services you’ve asked from us, which may include online services.
- Complying with applicable laws: We may process your personal information to comply with any legal obligation we’re subject to.
We may use your information to:
- Carry out market research and product development, which can include creating customer demographics and/or profiling. We may sometimes work with carefully selected business partners to do this.
- Continue to send marketing information, to customers who purchased a product before 25th May 2018 and did not opt-out, until such time as they have reviewed their marketing preferences (which can be done at any time).
- Develop and test the effectiveness of marketing activities.
- Develop, test and manage our brands, products and services.
- Study and also manage how our customers use products and services from our business partners.
- Manage risk for us and our customers.
This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.
- Consent: We may provide you with marketing information about our services or products where you’ve provided your consent for us to do so. You may opt-out of marketing at any time by e-mailing or telephoning your customer servicing team. Alternatively, you can also use the Contact Us section of our website.
- Special category (sensitive) data: Where you have consented, we will process any medical & health, racial & ethnic origin, genetic & biometric or sex life & sexual orientation information you have provided, and any other sensitive information obtained from a third party (e.g. your GP or other medical professional), solely for the purposes of allowing us to underwrite and administer your policy
Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.
How long do we keep your information for?
We’ll keep your personal information in accordance with our internal retention policies. We’ll determine the length of time we keep it for based on the minimum retention periods required by law or regulation. We’ll only keep your personal information after this period if there’s a legitimate and provable business reason to do so.
Who do we share your personal information with?
We’ll only disclose your information to:
- Third-party suppliers, contractors and service providers for the purposes listed under “How do we use your information” above.
- Selected third parties, so that they can contact you with details of the services that they provide, where you have expressly opted-in or consented to the disclosure of your personal data for these purposes.
- Our regulators, government
Additionally, we may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we’ll disclose your personal data to the prospective seller or buyer of such business or assets.
- If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- In order to enforce or apply the terms of any contract with you.
- If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
- To protect you and Bobatoo from financial crime, Bobatoo may be required to verify the identity of new and sometimes existing customers. This may be achieved by using reference agencies to search sources of information relating to you (an identity search). This will not affect your credit rating. If this fails, Bobatoo may need to approach you to obtain documentary evidence of identity.
If you’ve been introduced to us by another company we may share your information with them to enable them to:
- Carry out market research, statistical analysis and customer profiling.
- Where you have consented, send you marketing information by post, telephone, e-mail and SMS about their products and those of carefully selected third parties.
Transferring your data outside the EU
We’ll only transfer your data to a recipient outside the EEA where we’re permitted to do so by law (for instance, (A) where the transfer is based on standard data protection clauses adopted or approved by the European Commission, (B) where the transfer is to a territory that is deemed adequate by the European Commission, or (C) where the recipient is subject to an approved certification mechanism and the personal information is subject to appropriate safeguards, etc.).
Unfortunately, sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.
You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner’s website. If you wish to exercise any of these rights, please get in touch with your customer services team. Alternatively, you can also use the Contact Us section of our website.
|1.||The right to access the personal data that we hold about you|
|2.||The right to make us correct any inaccurate personal data we hold about you|
|3.||The right to make us erase any personal data we hold about you. This right will only apply where for example:
Where you object to the way we use your data, and there is no overriding legitimate interest
|4.||The right to restrict our processing of the personal data we hold about you. This right will only apply where for example:
Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.
|5.||The right to object to our processing of personal data we hold about you (including for the purposes of sending marketing materials to you)|
|6.||The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.|
|7.||The right to withdraw your consent, where we're relying on it to use your personal data (for example, to provide you with marketing information about our services or products).|
Contacts and complaints
If you have any concerns about the way we process your personal data, or are not happy with the way we’ve handled a request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:
First Contact Team
Information Commissioner's Office