Data Protection Privacy Notice

Last Updated: 20/06/2023 // V1.11

BACKGROUND:

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.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately. For information on how we share your data, please navigate to section 7.

  1. Definitions and Interpretation

    In this Policy the following terms shall have the following meanings:

    “Account”

    means an account required to access and/or use certain areas and features of Our Site.

    “Cookie”

    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.

    “Cookie Law”

    means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

    “Personal Data”

    means any 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 incorporates the definitions provided in the UK General Data Protection Regulation (“UK GDPR”).

    “We/Us/Our/the Company”

    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.
  2. Information About Us
    1. Our Site is owned and operated by the Company.
    2. We are registered as a Data Controller on the Data Protection Register with the Gibraltar Regulatory Authority (GRA) under registration number DP 011872.
    3. Our Data Protection Officer is Paul Crudgington, and he can be contacted by email at [email protected], by telephone on 0800 012 4041, or by post at Suite 3, Second Floor, Icom House, Irish Town, Gibraltar, GX11 1AA.
  3. What Does This Policy Cover?

    This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites, and We advise you to check the privacy policies of any such websites before providing any data to them.

  4. Your Rights
    1. As a data subject, you have the following rights under the UK GDPR:
      1. The right to be informed about Our collection and use of personal data;
      2. The right of access to the personal data We hold about you;
      3. The right to rectification if any personal data We hold about you is inaccurate or incomplete;
      4. The right to be forgotten;
      5. The right to restrict the processing of your personal data;
      6. The right to data portability;
      7. The right to object to certain types of processing; and
      8. Rights with respect to automated decision making and profiling.
    2. 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 have the right to lodge a complaint with the Information Commissioner’s Office (ICO) in the UK or the Gibraltar Regulatory Authority (GRA).
  5. What Data Do We Collect?

    Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:

    • Name
    • Date of birth
    • Contact information such as email addresses and telephone numbers
    • Smoker status
    • Demographic information such as postcode
    • IP address
    • Web browser type and version
    • Operating system
    • Referral site and browsing activity
  6. How Do We Use Your Data?
    1. 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 UK GDPR at all times.
    2. We may use your data for the following purposes:
      1. Supplying our services to you (we require your personal data to enter into a contract with you).
      2. Personalising and tailoring our services.
      3. Replying to enquiries and communications from you.
      4. Analysing use of Our Site to improve user experience.
      5. With your permission, contacting you by email or telephone with information, news and offers on services.
      6. Identity verification purposes – see section 7.2 below.
    3. You may withdraw your consent to marketing at any time and request deletion of your data.
  7. Do We Share Your Data?
    1. 7.1 Sharing with Third Parties
      We may share your personal data with selected third parties for the purposes of supplying the products and services you have requested. Where this is necessary, we ensure that your data is handled securely and in accordance with UK GDPR.
    2. 7.2 Identity Verification Processing by Smarter Cover Limited

      As part of our lead generation and referral process, we may share your personal data (name, date of birth, and address) with Smarter Cover Limited, a UK-authorised life insurance brokerage (FCA registration number 556053), located at First Floor, Bluebird House, Mole Business Park, Randalls Road, Leatherhead, Surrey, KT22 7BA.

      Smarter Cover Limited will act as the data controller for the purposes of carrying out a soft identity verification check on your personal data. This check is necessary to:

      • Meet regulatory requirements under anti-money laundering legislation, including Directive (EU) 2018/1673 (AML-6), applicable to certain life insurance products.
      • Facilitate the provision of life insurance products and services you have requested.
      • Improve the onboarding process and minimise disruption by confirming your identity early in the journey.

      Smarter Cover has contracted Lexis Nexis Risk Solutions as a data processor to perform the soft identity verification check on its behalf. Vero Cover Limited acts solely as a data processor in transferring your data for this specific purpose and does so only on Smarter Cover’s documented instructions.

      The lawful basis relied upon for this processing is:

      • Article 6(1)(b) UK GDPR – Processing necessary for steps prior to entering into a contract.
      • Article 6(1)(f) UK GDPR – Legitimate interests, specifically compliance with AML obligations and improving customer outcomes.

      This soft check uses only your name, date of birth, and address. It does not affect your credit score or your credit file and is used solely for identity verification purposes.

      For more information about how Smarter Cover Limited processes your data, please refer to Smarter Cover’s privacy notice.

  8. How and Where Do We Store Your Data?
    1. We only keep your personal data for as long as necessary.
    2. Your data will be stored within the European Economic Area (EEA).
    3. We have implemented appropriate security measures, including PCI-compliant scans and ISO 27001-aligned data controls, to safeguard your data.
  9. What Happens If Our Business Changes Hands?
    1. If Our business is transferred, your data will also be transferred where relevant. The new controller will only use your data for the same purposes and under the same terms as this Privacy Policy.
    2. You will be notified in advance and may request deletion of your data if you do not wish it to be transferred.
  10. How Can You Control Your Data?
    1. You may restrict our use of your data, particularly for marketing purposes, and can exercise your rights as set out in section 4.
  11. Your Right to Withhold Information
    1. You may access Our Site without providing any personal data. However, some features may require data submission.
  12. How Can You Access Your Data?

    You may request a copy of any personal data we hold about you free of charge by contacting us using the details in section 14.

  13. Contacting Us

    If you have any questions about Our Site or this Privacy Policy, please contact our Data Protection Officer:
    Email: [email protected]
    Telephone: 0800 012 4041
    Post: Suite 3, Second Floor, Icom House, Irish Town, Gibraltar, GX11 1AA

  14. Opting-Out, Withdrawing Consent, and Objecting to Processing

    You can withdraw consent or object to processing by contacting our DPO. We will process such requests as quickly as possible.

  15. Changes to Our Privacy Policy

    We may update this Privacy Policy periodically. Changes will be posted on Our Site, and your continued use will indicate acceptance of the revised policy.

  16. COMPLAINTS

    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 protected]. If unresolved, you may contact the Information Commissioner’s Office (www.ico.org.uk) or the Gibraltar Regulatory Authority (www.gra.gi). We treat any complaints very seriously and we would appreciate the opportunity to try to resolve any issues in the first instance.

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