This website https://nationwide.lifestyleservicesgroup.co.uk/index.php (the "Service") is operated by Lifestyle Services Group Limited, with mailing address of PO Box 98, Blyth, NE24 9DL, a member of the Assurant, Inc. group of companies (hereinafter, “We”, “Us”, “Our” or “Company”). Assurant General Insurance Limited is the data controller of your Personal Information in the context of the Service.
This Privacy Notice (“Notice”) describes how We will process and protect Personal Information relating to an identified or identifiable individual (“Personal Information”) when you use the Service, which allows users to create and manage an account (e.g., enter and update contact details, manage communication preferences and manage passwords and/or security settings), submit a claim, upload claims-related documents (for example, proof of purchase, police reports), access policy documents and forms (for example, view policy terms and conditions, print certificates of coverage, print claims forms), and contact customer support, and applies to your use of the Service. We also use the Personal Information to provide Our insurance or product services to you, to communicate with you, and to track usage of the Service and Our products and services. Your Personal Information shall be held and used in accordance with applicable legislation relating to the protection of Personal Information (the “Applicable Law”). Your Personal Information will be shared with other Assurant affiliates and service providers, some of which are located outside the EEA and are not subject to an adequacy decision of the European Commission.
This Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other services, please refer to the policies provided in association with each.
1. Personal Information We Collect
We collect your Personal Information in the following situations:
1.1 When you Create an Account
We collect Personal Information from you when you create an account on the Service. To create an account on the Service, We ask users to provide Us with their name, contact details (for example - postal code, email address, telephone and mobile numbers, contact preferences), banking information (for example – sort code, account number, type of account), date of birth, gender, security questions, and password. We will also collect your Internet Protocol (“IP”) address.
1.2 When you Submit a Claim
We collect Personal Information from you when you submit a claim. When you submit a claim, We may ask you to provide Us with your: contact details (for example, telephone number, address, delivery information), covered device or gadget information (for example, manufacturer, model, memory, colour), device or gadget identification number (for example, serial number, IMEI), proof of purchase (for example, receipt), network provider, contract type, and accidental damage (for example nature of incident) or loss details (for example, police report). If you submit a claim in respect of a device which has the same IMEI number as a previous claim, this will be flagged by Our fraud prevention database, which contains information (name, contact information, address and IMEI) entered by Us, other insurers, and fraud prevention agencies.
1.3 When you Submit a Payment
We collect Personal Information from you when you make a payment (for example, an excess payment). We ask you to provide Us with payment details: cardholder name, payment card number, CVC, and expiry date.
1.4 When you communicate with Us or contact Us for Customer Support
When you contact Our customer support team (for example, when you enquire about the status of your replacement device or repaired device), We will collect information that you provide to Us in your communications (such as the query or issue that you have raised).
1.5 When you access the Service
2. Purposes and Legal Basis for the Processing of your Personal Information
We process your Personal Information for the following purposes:
- To fulfil a contract, or take steps linked to a contract: this is relevant where you have entered into an insurance contract with Us (for example - where you submit a claim). This includes:
- providing the Service;
- verifying your identity;
- processing your claim;
- taking payment from you;
- making reimbursement payments to you; and
- communicating with you.
- As required by Us to conduct Our business and pursue Our legitimate interests, in particular:
- We will use your Personal Information to provide the Service and other products and services that you have requested, and respond to any comments or complaints you may send Us;
- We monitor use of the Service, and use your Personal Information to help Us to track and analyse preferences and trends, evaluate possible new features, functionality and services, and improve Our Service.
- We use Personal Information to help Us recognise you on the Service, improve your experience, increase security of Our networks and systems, and measure use and effectiveness of Our Service.
- We use Personal Information you provide to investigate complaints received from you or from others, about the Service or Our products and services. We also use this Personal Information to track potential issues (for example, issues with fulfilment of services) and trends to better serve you;
- We use Personal Information to make decisions about, and to effect, reorganisations or sales of all or part of Our business;
- We monitor customer accounts to prevent, investigate and/or report fraud, misrepresentation, or crime, in accordance with Applicable Law;
- We will use Personal Information in connection with legal claims (for example, relating to denial of an insurance claim), compliance, regulatory and investigative purposes (for example, theft and fraud investigations) as necessary (including disclosure of such information in connection with legal process or litigation);
- We use Personal Information of some individuals to invite them to take part in market research and customer surveys;
- We use Personal Information to send you information about Assurant products and services, such as customer experience surveys (where your consent is not required);
- Where you give Us consent:
- We place cookies and use similar technologies in accordance with Our Cookie Notice and the information provided to you when those technologies are used;
- On other occasions where We ask you for consent, We will use the data for the purpose which We explain at that time.
- For purposes which are required by law:
- In response to requests by government or law enforcement authorities conducting an investigation; and
- Responding to complaints where We are under a legal or regulatory obligation to adhere to a complaints handling procedure.
- Withdrawing consent
- Wherever We rely on your consent, you will always be able to withdraw that consent, although We may have other legal grounds for processing your data for other purposes, such as those set out above. Where you have given Us your consent, you can withdraw it by using the mechanism described to you at the time that your consent was obtained, or by contacting Us
3. Disclosure of Personal Information
3.1 Disclosure to Our Affiliates
We will disclose your Personal Information to other Assurant group companies for the purpose of performing tasks that directly relate to the provision of the Service. For example, We may share your information with Our affiliates to fulfil your claim (if you have an iPhone, We may use Our Assurant group company information systems to support sharing of your device IMEI with Apple, and may also share your name and contact details as necessary).
3.2 Disclosure to Our Service Providers and Partners
We employ third party companies and individuals to facilitate the Service (for example, customer support, customer communications, audit, application or database hosting, development, logistics, payment processing, other insurance companies (for example, reinsurers), and for fraud detection and prevention purposes. These third parties have limited access to your Personal Information to perform these tasks on Our behalf and are obligated to Us. The personnel of such third parties who use your Personal Information is limited to those individuals which are authorised to do so on a need-to-know basis and as necessary to provide these business services to Us. To fulfil your claim, We may share your name, contact details (including postal address, email address and mobile number), and IMEI of your covered device with the manufacturer. For example, if you have an iPhone, then We will share your device IMEI with Apple, and may also share your name and contact details as necessary. We do not authorise such third parties to disclose or use this Personal Information for other purposes.
3.3 Disclosure to Public Authorities
We may disclose your Personal Information if required for the purposes above, if mandated by law or if required for the legal protection of Our legitimate interests in compliance with Applicable Law.
3.4 Other Categories of Recipients
We may also disclose your Personal Information, usage information, and other information about you to parties acquiring part or all of Our assets, as well as to attorneys and consultants. Also, if any bankruptcy or reorganisation proceeding is brought by or against Us, your Personal Information may be considered a Company asset that may be sold or transferred to third parties.
4. International Transfers of Data
In providing the Service, Personal Information may be transferred to, and processed in, countries where data protection and privacy regulations do not offer the same level of protection as the European Economic Area (“EEA”) and other parts of the world.
Sharing Personal Information with Our affiliates involves transfers outside the EEA to the US. For example, if We share your data with other Assurant group companies to fulfil your claim, that data will be processed by Our affiliate located in the United States.
Sharing Personal Information with Our Service Providers and Partners involves transfers outside the EEA to the US. For example, if We share your data with Apple Distribution International, that data will be processed and managed by Apple, Inc. which is located in the United States.
Where Personal Information is transferred outside the EEA to a country that is not subject to an adequacy decision by the EU Commission, it is adequately protected by European Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests to Us
5. Your Choices and Rights
In some countries, you have the right to request access to, correction of, and deletion of your Personal Information, and to restrict the processing of your Personal Information, under Applicable Law. You also have the right to request a structured commonly-used and machine-readable copy of Personal Information that you have provided to Us for a contract or with your consent, and to ask Us to transmit (port) this Personal Information to another controller.
You may also object to Our processing of Personal Information in certain circumstances (in particular, where We don't need to process the information to meet a contractual or other legal requirement, or where We are using the data for customer experience surveying purposes (see section 2).
You can exercise any of your rights by contacting Us. In order to safeguard your Personal Information from unauthorised access, We may ask that you provide sufficient information to identify yourself prior to providing access to your Personal Information.
In certain situations, and subject to Applicable Law, We may not be able or obliged to comply with part or all of your individual requests. For example, We may not comply with an access request if doing so would reveal Personal Information about another person, or comply with a deletion request relating to information which We are required by law to keep or have compelling legitimate interests in keeping. Please note that We have the right to refuse requests which are manifestly unfounded or excessive (for example, due to their repetitive character).
If you have unresolved concerns, you have the right to complain to an EU data protection authority ('supervisory authority') where you live, work or where you believe a breach may have occurred.
To provide certain parts of the Service (for example - Claims Submission and Making Payment), the provision of Personal Information is mandatory: If relevant data is not provided, then We will not be able to provide certain parts of the Service. All other provision of your information is optional. If you do not wish to provide optional information, then your experience on Our website may be less personalised.
6. Communications from Us
We communicate with you through email and the Service. We will send you service-related communications (for example, “Your device has been shipped”), customer satisfaction and market research surveys.
You can change your email and contact preferences by contacting Customer Service or by contacting Us. Please be aware that you cannot opt-out of receiving service-related messages from Us.
7. Data Retention
For this website We typically delete logs and other backup information through the deletion process within 30 days of your last activity, except as noted in Section 5. Where We process registration data, We do this for as long as you are an active user of Our site and for 6 years after this. Where We process Personal Information in connection with performing a contract, We keep the data for 6 years from your last interaction with Us
8. Information Security
We have implemented safeguards designed to protect your Personal Information in accordance with industry standards.
We have measures in place to restrict access to Personal Information to those individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the Personal Information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide Personal Information collected through the Service to keep such information secure and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.
9. Important Information
9.1 Minimum age
We do not knowingly collect Personal Information from anyone under the age of 18. You must be at least 18 years of age to use the Service.
9.2 Changes to this Notice
We may update this Notice from time to time. If We make any material changes to Our Notice, We will notify you by email or by means of a notice through the Service, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use the Service. Please review changes carefully.
9.3 Contact Us
For customer enquiries, please contact Us at: Lifestyle Services Group, PO Box 98, Blyth, NE24 9DL, or call us.
We welcome your questions or comments regarding this Notice. Please write to Assurant General Insurance Limited (an Assurant group company), Data Protection Officer, PO Box 98, Blyth, NE24 9DL, or send Us an email at firstname.lastname@example.org. You may also write to Us at Assurant Privacy Office, Post Office Box 979047, Miami, FL 33197-9047, USA.
10. Cookies Notice
10.1 Improve User Experience
Some browsers offer a “Do Not Track” (“DNT”) signal whereby you may indicate your preference regarding tracking and cross-site tracking. Although We do not currently employ technology that recognises DNT signals, We will only process your Personal Information in accordance with this Notice.
10.2 Analyse Website’s Performance
We collect Personal Information, on an individual and collective basis, to track and analyse preferences and trends, improve the quality of the Service, evaluate possible new features, functionality and services, and improve Our Service. We collect information when you use Our website, and may use third party analytics tools to evaluate user traffic. For example, We collect information when you view a page or click on a link. Additionally, We collect log in information about devices used to access Our Service, including IP addresses.
10.3 What types of cookies are used on this website?
We use first party cookies on this website. The cookies used on Our website can be categorised in the following ways:
- Essential cookies: These cookies are essential in order to enable users to navigate the web site and use its features, such as accessing secure areas of the website. Without these cookies, services that you have requested, such as shopping baskets or e-billing, cannot be provided. These cookies don’t gather information about you that could be used for marketing or remember where you've been on the Internet.
- Performance cookies: These cookies collect information about how users use a website, for instance which pages users go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a user. The information these cookies collect is anonymous and only used to improve how a website works.
- Functional cookies: These cookies allow a website to remember preferences (such as language or region) and offer improved and customised functions. The information that these cookies collect can be anonymous and they may not record your browsing activity on other websites.
- Social Media Cookies: These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. These cookies are not within Our control. Please refer to the respective privacy policies for how their cookies work.
Some of Our web pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow Us to count users who have visited these pages. Web beacons collect only limited information which including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.
By using Our website, you agree that We can place these types of cookies on your device as set forth in this Cookies Notice. The table below explains the types of cookies We use and why.
|Cookie Purpose||Session cookies last only for the duration of your visit and are deleted when you close your browser. These facilitate various tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.|
|Cookie Name||_utma, _utmb, _utmc, _utmt, _utmz|
|Cookie Purpose||These cookies are used to collect information about how visitors use Our site, which We use to help improve it. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.|
|Choice||Click here for an overview of privacy at Google|
These cookies are used to collect information about how visitors use Our site, which We use to help improve it. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Click here for an overview of privacy at Google
10.4 How do I change my cookie settings?
If you prefer not to accept cookies into your browser, the help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, disabling cookies may result in certain parts of the website and resources not operating correctly or prevent you from taking full advantage of some of the features of the Service. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
Effective date: 16/05/2018