Data Protection Privacy Notice
Last Updated: 20/06/2023 // V1.11
Vero Cover Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means Personal Data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
means Vero Cover Limited, a limited company registered in Gibraltar under company number 112164, whose registered address is Suite 3, Second Floor, Icom House, Irish Town, Gibraltar, GX11 1AA and whose main trading address is A-B Neptune House, Marina Bay, Gibraltar, GX11 1AA.
- Our Site is owned and operated by the Company.
- We are registered as a Data Controller on the Data Protection Register with the Gibraltar Regulatory Authority (GRA) and our registration number is DP 011872.
- Our Data Protection Officer is Paul Crudgington, and he can be contacted by email firstname.lastname@example.org by telephone on 08000124041 or by post at Suite 3, Second Floor, Icom House, Irish Town, Gibraltar, GX11 1AA.
- As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
- If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 and we will do our best to resolve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- date of birth;
- contact information such as email addresses and telephone numbers;
- smoker status;
- demographic information such as post code;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under GDPR at all times. For more details on security see section 8, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring Our services for you;
- Replying to emails from you;
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
- With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email or telephone with information, news and offers on services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- 96 Months from the date of the last submission of data.
- We will contract a third party to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
- You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
- We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
- Steps We take to secure and protect your data include:
- PCI Compliant Data Scans Run at regular intervals
- ISO 27001 Compliant Data
- In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
- In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You have the right to ask for a copy of any of your personal data held by Us (where such data is held) Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us using the contact details below in section 14.
Our aim is not to give you cause to complain. However, if you feel you do have cause to complain, you are welcome to submit your concerns to us by email at email@example.com. Under the GDPR you have the right to complain to Information Commissioner’s Office (www.ico.org.uk) in the UK or the Gibraltar Regulatory Authority (www.gra.gi) in Gibraltar. We treat any complaints very seriously and we would appreciate the opportunity to try to resolve any issues in the first instance.