Privacy
1 What is this notice?
Co-op Insurance Services take your privacy seriously and this fair processing notice (Notice) sets out how we will use and share your personal information and explains your data protection rights and how to contact us. In this Notice, references to you or your shall mean you as a customer or a prospective customer of the pet insurance product (Pet Insurance) which is arranged, administered and underwritten by Allianz Insurance plc. If you decide to purchase Pet Insurance, this Notice should be read together with your policy documents.
2 Who are we?
We are Co-op Insurance Services Limited trading as Co-op Insurance Services (which is part of the Co-op Group) and we are classed as a "data controller" of your personal information. Our registered office address is at CIS Building, Miller Street, Manchester M60 0AL. When we use terms such as we, us and our in this Notice, we mean Co-op Insurance Services.
Our Data Protection Officer (DPO) can be contacted by emailing dataprotectionqueries@cfs.coop or by letter to Data Protection Officer, Co-op Insurance Services Limited, CIS Building, Miller Street, Manchester M60 0AL.
We are introducing you to Allianz Insurance plc (Allianz) who are also a data controller of your personal information. Allianz will collect your personal information in order to provide you with your Pet Insurance and will share it with us for marketing and product management purposes. Further information about how Allianz uses your personal information can be accessed here. It is important that you read Allianz's privacy policy because it sets out your rights when it comes to their handling of your personal information, and also explains their privacy and data protection obligations.
3 What kinds of personal information does Allianz provide to us?
When you apply for a quotation, purchase Pet Insurance, renew your policy, make a claim and/or complaint, Allianz collect certain information from you such as your name, gender, marital status, address, email address, internet protocol address, contact telephone number and bank account details. Allianz shares this personal information with us for the purposes set out below.
4 How do we use your personal information?
We may use your personal information:
- where applicable, to fulfil Co-op Group membership requirements in relation to our Co-op Group membership scheme;
- to send to you Co-op Group membership offers where appropriate;
- to manage the overall performance of the Pet Insurance account;
- to monitor the performance of Allianz;
- to offer you incentives from time to time;
- to ask for your feedback, assess customer service and satisfaction and to improve our overall operations;
- to develop new services and products for you;
- to communicate with you, where you have consented to receive communications or by sending you information about similar Co-op Group products or services which we think may be of interest to you. We will not send you marketing communications if you have opted out to receive marketing. You will be able to opt-out of such communications at any time by contacting us using the details at section 12 of this Notice;
- to comply with our legal obligations; and
- to help us improve our service and our communications to you, so that we can contact you at the most appropriate time with relevant offers.
5 What is our legal basis for using your personal information?
We will only use your personal information where it is permitted by law and where:
- we need to use your personal information to comply with our legal or regulatory obligations;
- you have given us consent to use your personal information (if consent is needed); and
- it is in our interests or the interests of Allianz to fulfil their contractual obligations to you and where there is no disadvantage to you.
6 Who do we share your personal information with?
We will share your personal information with:
- service providers and third party partners who process and store data on our behalf;
- professional advisors;
- law enforcement, taxation and legal authorities; and
- any member of the Co-op Group, which means Co-operative Group Limited, and other companies which may be added to the Co-op Group from time to time.
We may also share your personal information with third parties in the event that our Co-op business or substantially all of its assets are acquired by a third party and if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or to protect our rights, property, or the safety of our employees, customers, members or others.
7 Will we transfer your personal information outside of the UK?
We may need to transfer your personal information outside of the UK to countries where data protection laws may not provide the same level of protection as those in the European Economic Area. We shall ensure that any such transfers are lawful and that your personal information is kept secure.
8 How long will we keep your personal information for?
We keep personal information for as long as we need to for the purposes we have set out above. Usually, we will retain your information for up to seven years, unless there is an exceptional business purpose in which case this time period needs to be extended. If you would like further information about our retention procedures, please contact us using the details at section 12 of this Notice.
9 What are your rights?
Data protection laws give you a number of rights as set out below. If you would like to exercise any of your rights in relation to the personal information we hold about you, please contact us using the details at section 12 of this Notice.
Please note that we can only assist you with exercising your rights in relation to the personal information that we hold about you. If you would like to exercise your rights in respect of the personal information that Allianz collected from you and holds about you, please contact Allianz directly using the details at section 12 of this Notice.
Right to access your personal information: you may request access to a copy of your personal information. Please send all requests for access to us in writing.
Right to withdraw consent: if you have given us consent to use your personal information to send you marketing, you can withdraw your consent at any time.
Right to rectification: you may ask us to rectify any inaccurate information we hold about you. If you would like to update the personal information we hold about you, please contact us.
Right to erasure: you may ask us to delete your personal information. If you would like us to delete the personal information we hold about you, please contact us, specifying why you would like us to delete your personal information.
Right to portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or ask for us to send such personal information to another data controller.
Right to restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
Right to object: you may object to our processing of your personal information pursuant to this Notice. Please contact us, providing details of your objection.
Right to make a complaint: you may make a complaint about our data processing activities by contacting us using the details at section 12 of this Notice. Alternatively, you may make a complaint to the UK supervisory authority, which is the Information Commissioner's Office, by visiting their website at www.ico.org.uk, by phoning 0303 123 1113 (local rate) / 01625 545 745 (national rate), or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
10 How will we keep your personal information secure?
We will treat all of your personal information in strict confidence and we will take all reasonable steps to keep your personal information secure once it has been transferred to our systems. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information. Please note that we cannot guarantee the security of any data you disclose to us online. You accept the inherent security risks of providing information and dealing online and will not hold us responsible for any loss or damage that you incur.
11 Changes to this notice
We may modify this Notice from time to time, so please review it regularly. We will let you know when we make any material changes to this Notice by means of notice on our website or if appropriate, by contacting you directly. This Notice was last amended on 8 May 2018.
12 How can we be contacted?
If you have any queries relating to this Notice or our use of your personal information or wish to exercise any of your rights, please contact our Data Protection Officer by email at dataprotectionqueries@cfs.coop or by letter to Data Protection Officer, Co-op Insurance Services Limited, CIS Building, Miller Street, Manchester M60 0AL.
13 How can Allianz be contacted?
If you have any queries about how Allianz uses your personal information please contact Allianz directly by emailing dataprotectionofficer@allianz.co.uk, by letter to Data Protection Officer, Allianz Insurance plc, 57 Ladymead, Guildford, Surrey GU1 1DB or by calling 0330 102 1837.
