About Animal HealthcarePVG is a group of companies made up of Animal Healthcare Company Limited and other companies it owns and controls. For simplicity throughout this policy, 'we' and 'us' means Animal Healthcare. Depending on which of our products and services you ask us about, buy or use, different companies within Animal Healthcare will process your information.
How is your personal data collected?We use different methods to collect data from and about you including through: Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone (we may record or monitor phone calls to make sure we are keeping to legal rules, codes of practice and internal policies, and for quality assurance purposes), email or otherwise. This includes personal data:
- You provide when you:
- Apply for our products or services
- Create an account on our websites
- Subscribe to our service or publications
- Request marketing to be sent to you
- Enter a competition, promotion or survey
- Give us some feedback or comments on the services we provide
- Provided by a family member, or someone else acting on your behalf
- Our partners, in relation to your products or services, such as people providing you with apps, medical treatment, dental treatment or health assessments
- Organisations who carry out customer-satisfaction surveys or market research on our behalf, or who provide us with statistics and other information (for example, about your interests, purchases and type of household) to help us to improve our products and services
- Sources which are available to the public, such as the edited electoral register or social media
If we provide you with health plan products and services, we may collect information from:
- The main member, if you are a dependant under a family policy
- Your employer, if you are covered by a policy your employer has taken out
- Other third parties we work with, such as agents working on our behalf, other insurers and reinsurers, actuaries, auditors, solicitors, translators and interpreters, tax advisers, debt-collection agencies, credit-reference agencies, fraud-detection agencies (including health-insurance counter-fraud groups), regulators, data-protection supervisory authorities, health-care professionals, other health-care providers and medical-assistance providers
- Your employer, if you are covered by a contract for services your employer has taken out or if we are providing occupational health services
- Brokers and other agents (this may be your broker if you have one, or your employer's broker if they have one)
- Those paying for the products or services we provide to you, including other insurers, public-sector commissioners and embassies
The data we collect about youPersonal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
- Health Data includes any information relating to your mental or physical health including details and conditions surrounding treatment received
- Contact Data includes billing address, email address and telephone numbers
- Financial Data includes bank account details and details about your payments
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
- Usage Data includes information about how you use our websites, products and services
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences
If you fail to provide personal data
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 that 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 products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into, or have entered into with you
Where it is necessary for our legitimate interests* (or those of a third party) and your interests and fundamental rights do not override those interests
Where we have a legal or regulatory obligation to use your personal information, for example, when our regulators, the Prudential Regulatory Authority, (PRA), the Financial Conduct Authority (FCA) or the Information Commissioner's Office (ICO) ask us to maintain certain records of any dealings with you
Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims, or where we want to make any claims ourselves
Where we need to use your personal information for reasons of substantial public interest, such as investigating fraudulent claims and carrying out fraud, credit and anti-money laundering checks
Where we have a specific legal exemption to process sensitive personal data for insurance purposes. This exemption applies where we need to process your health data
Where we have an appropriate legitimate business need to use your personal information such as maintaining our business records, developing and improving our products and services, all whilst ensuring that this business need does not interfere with your rights and freedoms and does not cause you any harm
Where we need to use your sensitive personal information such as health data because it is necessary for your vital interests, an example would be a life or death matter
Purposes for which we will use your personal data
We have set out below, in a table, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note, that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity (b) Health (c) Contact||(a) Performance of a contract with you (b) Necessary for reasons of substantial public interest|
|To process and deliver your product including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) paying claims to you||(a) Identity (b) Health (c) Contact (d) Financial (e) Transaction (f) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Necessary for reasons of substantial public interest|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity (b) Health (c) Contact (d) Profile (e) Usage (f) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) (c) Necessary for reasons of substantial public interest|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Health (c) Contact (d) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (c) Necessary for reasons of substantial public interest|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Health (c) Contact (d) Profile (e) Usage (f) Marketing and Communications (g) Technical||(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Necessary for reasons of substantial public interest|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Health (c) Usage||(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) (b) Necessary for reasons of substantial public interest|
|To make marketing suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Health (c) Contact (d) Technical (e) Usage (f) Profile||(a) Consent, where the individual has given clear consent for us to process their personal data for a specific purpose (b) Necessary for our legitimate interests (to develop our products/services and grow our business) (c) Necessary for reasons of substantial public interest|
Opting outYou can ask us to stop sending you marketing messages at any time by contacting us at email@example.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.
Automated decision-making and profiling
Automated individual decision making is a decision made by automated means without any human involvement. Automated individual decision-making does not have to involve profiling (automated processing of your information to help us evaluate certain things about you), although it often will do. Sometimes we may use automation and profiling to evaluate information about you, which will enable us to:
Determine whether an application for a product is accepted by us
Understand claiming behaviours and patterns
Tailor our marketing material to your needs
Tailor our pricing, products and services to provide you with a more efficient, consistent and fair customer experience
Identify and investigate fraudulent activity
We carry out a data protection impact assessment (DPIA) to consider and address the risks before we start any new automated decision-making or profiling
We tell our customers about the profiling and automated decision-making we carry out, what information we use to create the profiles and where we get this information from
Change of purpose
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 reason and that reason is compatible with the original purpose. If you wish to get 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, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal dataWe may have to share your personal data with the parties set out below for those purposes set out in table 'Purposes for which we will use your personal data':
Internal Third PartiesOther companies within Animal Healthcare acting as joint controllers or processors and who provide IT and system administration services and undertake leadership reporting.
External Third Parties
Service providers acting as processors who provide IT and system administration services
Professional advisers acting as processors or joint controllers based in the United Kingdom including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances
Fraud detection agencies and other third parties who operate and maintain fraud detection registers
The Financial Ombudsman Service and regulatory authorities such as the Financial Conduct Authority, the Information Commissioner's Office and the Prudential Regulation Authority
For members with policies arranged by a company or offered via an employer we may share data with that employer where appropriate
International transfersSome of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. 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 the same protection it has in Europe
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield
Data securityWe 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.
How long will you use my personal data for?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. If you would like more information about how long we will keep your information for, please contact us at firstname.lastname@example.org
Your legal rightsUnder certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
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
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
Where any automated decision making and profiling has taken place, you have the right to obtain human intervention, express your point of view, and obtain an explanation of the decision and to challenge it.
No fee usually requiredYou will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from youWe may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respondWe try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Animal Healthcare Limited
New Bond House