Privacy Policy

The personal data we collect and process includes:

• Identity: title, name, date of birth, your pet's name

• Contact: email address, postal address and telephone numbers (current and previous)

• Financial: bank details

• Transaction: details about payments to and from you and other details of policies (including any claims), products and services you have with us.

• Profile: usernames or passwords for any online accounts you have set up with us

• Usage: Information about how you use our website, policies, products and services

• Technical: Data from you visiting our websites such as:

  • IP addresses

  • Browser type and version

  • Domain

  • Device type

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special Category Data

We do not actively collect special category data. We will only hold special category data if this is information you have volunteered to us and provide your consent for us to retain such data, for which will help us service your insurance contract with us more efficiently.

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 an insurance quote and/or policy). 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 use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• create an account on our website;

• enter a survey; or

• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy which can be located on any of our websites, for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data:

  • (a) Analytics providers such as Google Analytics; and

  • (b) HotJar tracking software.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

Promotional offers from us

We will not send you direct marketing communications. When you use our website to obtain an insurance quotation, we will automatically opt you out of direct marketing communications; however, we may utilise your identity, contact, technical, usage, and profile data to reach out and offer support in converting your quotation into a policy.

Third-Party Marketing

We will share your personal data with Lloyds Banking Group and where you have agreed to receive marketing from them, your contact details will be used by them so they can provide this marketing to you, and carry out analysis to determine which products may be of interest to you. If you decline marketing or later change your mind about receiving marketing, they will hold some details to keep a record of your choices and ensure these are honoured. Find out more about which companies form part of the Lloyds Banking Group here: https://www.lloydsbankinggroup.com/who-we-are.html

We may sometimes use an automated decision-making tool to assess claims where they have met a specific criterion. We utilise the information resulting from this to complete the assessment and make payment. You can ask for human intervention at any time by contacting claims@pet.lloydsbank.com. We also use automated decisions during the quote process, and you have rights over these decisions.

We may sometimes use your data for profiling for purposes other than marketing or making automated decisions about you. This is limited to the essential services we provide in order for us to manage our relationship with you. We may use speech analytics on recorded telephone calls to help us identify vulnerable customers and complaints, deliver training and ensure quality control. This data is reviewed manually. You have the right to object to us using your data in this way. Please see the 'What are your rights' section, and the 'How to contact us' section for details about how to do this.

We may share your data outside the UK; however, we do not transfer any data outside of the European Economic Area (EEA). Any personal data shared outside of the UK is done so in line with the relevant data protection laws.

General Third Parties:

• Our approved suppliers and contractors in order to be able to service our insurance policies effectively.

• Our insurers, legal advisors or other third parties who need access to it in the context of managing, investigation or defending claims or complaints.

• Your vet and/or therapist, to allow them to up-date your records that your pet is insured with us and/or, if they are going to treat your pet, to contacts us about your policy.

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

Specific Third Parties:

• Lloyds Bank Insurance Services Ltd for the purpose of complying with the Agreement we have in place with them.

• Ecclesiastical Insurance Office plc in relation to any third party liability insurance cover you have within your insurance policy for your dog.

Other:

• Regulatory or government bodies including police forces, local authorities or council, fraud prevention agencies, The Financial Conduct Authority, The Prudential Regulation Authority, the Swedish Financial Supervisory Authority (Finansinspektionen), The Financial Ombudsman Service, and His Majesty's Revenue & Customs (HMRC) when it is necessary to do so to ensure compliance with relevant legislation.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

All individuals have rights under data protection legislation, which are listed below. Agria have measures and processes in place to deal with any requests made when exercising these rights.

Right to be informed

You have the right to be informed about the collection and use of your personal data. This information must be concise, transparent, intelligible, easily accessible, and it must be in clear and plain language. We provide this to you in the form of this privacy policy.

Right of access

You can request all personal data that we hold on you. You have the right to contact us to request this using one of the contact methods stated below. We will review this and provide you with the information we have at the earliest opportunity, however, if the request is complex, we will contact you within 30 days to explain this and we may charge a fee for this if the request is excessive and/or manifestly unfounded. This right is also known as a 'subject access request'.

Right to rectification

You have the right to rectification if your personal data is inaccurate or incomplete. We strive to ensure that we have the most accurate and up to date data, however, please advise us as soon as possible, if any of the information we hold on you is inaccurate, and we will rectify it.

Right to erasure

You can request that your personal data is removed or deleted where there is no legal basis or compelling reason for this data to be processed any longer. This right is more commonly known as the 'right to be forgotten'.

Right to restrict processing

You have the right to request that the processing of your data is restricted in circumstances such as when you contest the accuracy of the data or when the processing is unlawful.

Right to data portability

Data portability allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.

Right to object

You have the right to object to the processing of your personal data if you do not wish for it to be used for direct marketing purposes, and we must act on this. You can also object to any use of information where we have given 'legitimate interest' as our reason for using it. You must provide us with the reason for the objection and how it affects you as an individual.

Right not to be subject to a decision based solely on automated processing

You have the right to ask for human intervention where a decision has solely been or is due to be made by automated means.

Where you have provided consent for us to process the data that we hold on you, you have the right to withdraw your consent that you provided to us at any time. If you have provided us with your explicit consent to process your data, you can withdraw this at any time.

You have the right to lodge a complaint about the processing of your personal data with a Supervisory Authority. The relevant Supervisory Authority is The Information Commissioners Office (ICO), please visit their website which advises you of the best method to contact them, www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

We will keep your personal data and telephone conversations for a minimum of 7 years and up to 11 years after you cancel your policy or after the last claim is closed, whichever is the latter. We are required to retain your data for the amount of time as required by law or in order to defend potential legal claims. For all personal data that we retain, 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.

We have a Data Protection Manager who has a high-level responsibility for monitoring compliance with all relevant data protection regulations and is the lead contact for liaison with The Information Commissioners Office (ICO). To exercise any of your rights mentioned above or with any specific queries on the personal data we hold on you, please contact us by post or email using the details below: