1. Who to contact about your Personal Information
If you have any questions about our use of your Personal Information you can e-mail: firstname.lastname@example.org or write to the Office Manager at: Scotts Trading, North Dorset Business Park, Sturminster Newton, Dorset, DT10 2GA.
2. Personal Information that we collect
Depending on your relationship with us (for example, as a consumer policyholder; non-policyholder insured or claimant; witness; commercial broker or appointed representative; or other person relating to our business), Personal Information collected about you and your dependants may include:
- General identification and contact information
Your name; address; e-mail and telephone details; gender; marital status; family status; date and place of birth; passwords; educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.
- Identification numbers issued by government bodies or agencies
Social Security or national insurance number; passport number; tax identification number; military identification number; or drivers or other license number.
- Financial information and account details
Payment card number; bank account number and account details; credit history and credit score; assets; income; and other financial information.
- Medical condition and health status
Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.
- Other sensitive information
In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organisation). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).
- Telephone recordings
Recordings of telephone calls to our representatives and call centres.
- Information to investigate crime, including fraud and money laundering
For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
- Information enabling us to provide products and services
Location and identification of property insured (for example, property address, vehicle license plate or identification number); travel arrangements including reservation numbers; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; and other insurance you hold.
- Marketing preferences and customer feedback
You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.
3. How we use personal information
We use this Personal Information to:
- Communicate with you and others as part of our business;
- Send you important information regarding changes to our policies, other terms and conditions, the Site and other administrative information;
- Make decisions about whether to provide insurance; provide insurance and assistance services, including claim assessment, processing and settlement; and, where applicable, manage claim disputes;
- Assess your eligibility for payment plans, and process your premium and other payments;
- Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers);
- Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks;
- Carry out market research and analysis, including satisfaction surveys;
- Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed;
- Personalise your experience on the Site by presenting information and advertisements tailored to you;
- Identify you to anyone to whom you send messages through the Site;
- Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully;
- Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting, billing and collections, IT systems, data and website hosting, business continuity, and records, document and print management;
- Resolve complaints, and handle requests for data access or correction;
- Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism, comply with legal process, and respond to requests from public and governmental authorities (including those outside your country of residence); and
- Establish and defend legal rights, protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
4. International Transfer of Personal Information
Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries (including the United States and other countries that have a different data protection regime than is found in the country where you are based). For example, we may transfer Personal Information in order to process international travel insurance claims and provide emergency medical assistance services when you are abroad. We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities.
5. Sharing of Personal Information
Scotts Trading & Complete VPI Ltd may make Personal Information available to:
- Other insurance and distribution parties
In the course of marketing and providing insurance, and processing claims, Scotts Trading & Complete VPI Ltd may make Personal Information available to third parties such as other insurers, reinsurers, insurance and reinsurance brokers and other intermediaries and agents, appointed representatives, distributors, affinity marketing partners, and financial institutions, securities firms and other business partners.
- Our service providers
External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors, travel and medical assistance providers, call centre service providers, IT systems, support and hosting service providers, printing, advertising, marketing and market research and analysis service providers, banks and financial institutions that service our accounts, third-party claim administrators, document and records management providers, claim investigators and adjusters, construction consultants, engineers, examiners, jury consultants, translators, and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
- Governmental authorities and third parties involved in court action
Scotts Trading & Complete VPI Ltd may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies), and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our
rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
- Other Third Parties
We may share Personal Information with payees, emergency providers (fire, police and medical emergency services), retailers, medical networks, organisations and providers, travel carriers, credit bureaus, credit reporting agencies, and other people involved in an incident that is the subject of a claim, as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganisation, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock. To check information provided, and to detect and prevent fraudulent claims, Personal Information (including details of injuries) may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to detect, prevent and investigate fraud.
Personal Information may also be shared by you, on message boards, chat, profile pages and blogs, and other services on the Site to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public information, and may be available to visitors to the Site and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Site.
Scotts Trading & Complete VPI Ltd will take appropriate technical, physical, legal and organisational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. (See the “Who to Contact About Your Personal Information” section above.)
When Scotts Trading & Complete VPI Ltd provides Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information.
7. Retention of Personal Information
8. Personal Information of other individuals
9. Marketing Preferences
It is company policy not to market any information to the Policyholder/Data Subject.
We capture and retain customer data for the purposes of handling claims and/or the administration of insurance only. The data will not be used for any other purpose and we confirm no rights to the data other than administration and/or claims handling.
We do not, and have no intention to, carry out any marketing to customers, therefore any ‘Opt Out/In’ preferences would be relevant.
10. Access and correction requests, questions and concerns
In certain countries, an individual may have the right to access, correct, object to the use of, or request deletion or suppression of Personal Information on certain grounds. Please contact us as set out in the “Who to Contact About Your Personal Information” section above with any such requests or if you have any questions or concerns about how we process Personal Information. Please note that some Personal Information may be exempt from access, correction, objection, deletion or suppression rights in accordance with local privacy and data protection laws.
11. Other information we collect through the site
“Other Information” is any information that does not reveal your specific identity, such as:
- Browser information;
- Information collected through cookies, pixel tags and other technologies;
- Demographic information and other information provided by you; and
- Aggregated information.
Other information we collect
We and our third-party service providers may collect other information in a variety of ways, including:
- Through your internet browser:
Certain information is collected by most websites, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, time of the visit and the page(s) visited. We use this information for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
- Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to recognise your computer and to collect information such as internet browser type, time spent on the Site, pages visited, language preferences and relevant country website. We may use the information for security purposes, to
Below is a description of all the cookies we use on our UK websites, what they do, what data about you they collect and what we use them for:
- Geo Location cookie – When a visitor visits one of our sites for the first time we read their location from their IP address and use this information to assume the country site that they want to visit. This method is not entirely accurate, however, so when they navigate to a particular country site we use a cookie to store this information and to store the language that they chose to view the site. The next time they visit the site we read the cookie and present the same country and language version they used on your last visit. This has the intended benefit that they don’t need to reselect the country site they need each time they come to the site. No Personal Information is collected or used by the cookie.
- Site Catalyst cookie (by Adobe) – This cookie enables us to collect and analyze data about how visitors arrive at our site and then how they interact with our site, including products they may search, content they may view, and the steps leading up to a completed or abandoned sale. We use this aggregated information to adapt our sites to better serve their and other users’ needs and interests, and to provide more relevant and useful information. The cookie is placed on a visitor’s PC on a temporary basis only. The cookie does not collect or use their Personal Information. Instead, it logs an anonymous code which identifies users and this code “follows” the user in their journey through the site. We use the aggregated and anonymous information for statistical analysis.
- DoubleClick cookies – We place a tracking pixel cookie on to all site visitors’ PCs, for the purpose of our banner advertising activity. We use these cookies to know that a visitor has been on our site before and to then place display an appropriate banner ad on to an affiliated network website. No Personal Information is collected. One of the advertisement companies that we use is Google, Inc, trading as DoubleClick. For more information on the DoubleClick cookie, or to opt out from the DoubleClick advertisement cookie please visit: http://www.google.com/privacy/ads/.
- Affiliate cookie – We use a tracking pixel cookie, which is put on a visitor’s PC and collects only the transaction ID (which identifies the any affiliated website the visitor has come from) and a time and date stamp. This enables our affiliate network to track affiliated sales and ensure an affiliate is credited for a sale referred to us. It does not involve any passing of Personal Information.
You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products.
Adobe’s Omniture service, including how to Opt-Out, go to http://www.omniture.com/privacy/policy#optout.
- From you: Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you.
- By aggregating information: We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code).
Please note that we may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat other information as Personal Information under applicable law, then, in addition to the uses listed in the “Other Information We Collect” section above, we may use and disclose other information for all the purposes for which we use and disclose Personal Information.
12. Third party websites
13. Use of site by minors
The Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information directly through the Site.