About this Privacy Notice
This privacy notice is made available to you by the administrator and the provider of your product, as identified below, when acting as the data controller of your personal information (collectively, “We”, “Us”, “Our”). Please read this privacy notice to understand how We, collect, use and protect the personal information that you provide to Us in the context of Our provision of products and services to you.
We are committed to preserving the privacy of Our customers in accordance with applicable data protection law.
Who We are
- TWG Services Limited, registered in England & Wales, company number 1883565, registered office Twenty Kingston Road, Staines upon Thames, Surrey TW18 4LG, authorised and regulated by the Financial Conduct Authority.
Provider for insurance products
- London General Insurance Company Limited, registered in England & Wales, company no. 1865673, registered office Twenty Kingston Road, Staines-upon-Thames, Surrey, TW18 4LG, authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority; or
- London General Life Company Limited, registered in England & Wales, company no. 2443666, registered office Twenty Kingston Road, Staines-upon-Thames, Surrey, TW18 4LG, authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.
Provider for non-insurance products
- The Warranty Group Services (Isle of Man) Limited, registered in the Isle of Man, company no. 094279C, registered office St George’s Court, Upper Church Street, Douglas, Isle of Man, IM1 1EE;
Personal Information We Collect from You
We may collect and use the following personal information from you as part of providing Our products and services to you:
- Name and contact details (e.g. postal address, phone number, email address, company name);
- Policyholder information (e.g. policy number, certificate number, bank account number, payment card data, billing and payment history);
- Claims information (claim number, date of loss and reason, call history, loss details, police reference number and supporting documentation);
- Covered device information (e.g. make, model, serial number, registration number, vehicle identification number);
- Records of any correspondence regarding any specific enquiry; and
- Feedback that you provide on Our products and services (including through customer experience surveys).
Some of Our products may involve the confidential processing of more sensitive special categories of data such as medical information. Such data will be processed only for the purposes of meeting Our obligations to you and strictly in line with the additional legal protections applying to such data.
You can choose whether you provide this information to Us. It may be that We will be unable to provide specific products or services to you if you do not provide certain information to Us.
Personal Information We Collect From Other Sources
We also collect and use personal information about you from third parties through whom you have procured an insurance or service product.
We will receive your name, contact information (including postal address and phone number), customer number and policy information (e.g., level of cover) from Our business partner (through whom you have procured an insurance or service product) to enable Us to administer and perform your contract of insurance with Us.
We also receive information about you (relating to your identity and previous claims made) from fraud prevention agencies and similar organisations to help Us make decisions on insurance policies and claims for you; trace debtors, recover debt, prevent fraud and to manage your insurance policy and any claims; check your identity to prevent money laundering; and undertake additional fraud searches, where necessary in pursuit of Our legitimate interests in protecting Our business from fraudulent activity and recovering sums due.
How We Use Your Personal Information
We use your personal information for the following purposes:
- Performance of a contract. Administration of your insurance cover or service contract, performance of Our obligations towards you and provision of the benefits under the insurance cover or service contract, including claims management. We use your information for these purposes where necessary for the performance of your contract with Us.
- Overriding Legitimate Interests. For statistical analysis, performing internal administrative functions, handling customer enquiries, managing customer relationships, evaluating the appropriateness of Our products and services, or to contact you (by post, mobile phone, text, or email) to provide you with information about expiry and renewal dates, important changes to Our products and services, or to obtain your views, for example by asking you to complete a customer satisfaction survey. We use your information for these purposes where necessary for Our legitimate interests (monitoring and improving Our offerings and Our customer experience and administering Our internal processes) in line with Our balancing tests. Our legitimate interests also include risk evaluation and management (including operational risk), debt recovery, fraud and payment default prevention and evidence management. We use your information for these purposes where necessary for pursuit of Our legitimate interests (protecting Our business from fraudulent activity and recovering sums due).
- Compliance with legal obligations. We use your information for these purposes where necessary for compliance with Our legal obligations Anti-money laundering, anti-terrorism efforts and sanctions screening.
How We Share Your Personal information
Your personal information may be disclosed to the following parties on a need-to-know basis:
- Other companies in Our group of companies: companies controlled by, or under common control with Our parent company Assurant, Inc. located in the United States, in the United Kingdom and the European Economic Area. We will disclose your personal information to Our affiliate companies for the purpose of performing tasks that directly relate to the provision of the Service.
- Third party suppliers of products or services, automobile dealerships or manufacturers (including consultants, couriers, repairers, other insurances companies, reinsurers) engaged by you or by Us in the purchase or performance of the insurance cover, service contract or to check your details in the industry claims review systems.
- Public Authorities: if required by law or for the legal protection of Our legitimate interests in compliance with applicable law We may disclose your Personal information. As part of the prevention of the fight against money laundering and terrorist financing, this data may also be shared between the Group's legal entities that may be located within and outside the European Union, in order to enrich their local screening processes and implement a common approach to the classification of customer risks throughout the Group.
- Other organisations and public bodies including law enforcement agencies in order to prevent or detect fraud or other criminal activity and to satisfy our legal and regulatory obligations where required and allowed under the applicable data protection law. For example, if you give us false or inaccurate information and we suspect fraud, we record this with fraud prevention agencies.
- An acquirer, successor, or assignee of our company as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
Where your Data is Processed
In the context of the purposes described above, your personal information will be transferred to, and processed in countries where data protection and privacy regulations do not offer the same level of protection as in the United Kingdom and other parts of the world.
Where Personal Information is transferred outside the United Kingdom to countries that are not considered to ensure an adequate level of protection of personal information, We will ensure that appropriate International Data Transfer Clauses are in place for those countries with privacy laws that do not have adequate protection. We may also rely on Our vendor’s Binding Corporate Rules. You may request information about these international transfers, and/or request to obtain a reference to the safeguards used to protect the personal information or a copy of those safeguards using the contact details provided below.
How Long We Keep Your Personal Information
Your personal information will in principle be retained no longer than necessary for the purposes we collected it. This means that your personal information will in principle be retained no longer than 6 years after termination or cancellation of your insurance cover or service contract to respond to questions, complaints, or enquiries. However, We may retain your personal information longer if this is required to comply with a law or regulation to which We are subject or necessary for Us to protect or exercise Our rights, to the extent allowed under applicable data protection law.
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 information. We maintain physical, electronic, and procedural safeguards. However, no method of transmission over the internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.
Your Rights and Choices
You have the following rights regarding on your Personal Information:
- Right to access information about how We process your Personal Information, including the categories of personal data We process, recipients of your Personal Information, and purposes for Our processing.
- Right to rectification of inaccurate Personal Information concerning you, as well as, taking into account the purposes of the processing, the right to have incomplete Personal Information completed.
- Right to erasure (deletion) of Personal Information concerning you where: (a) the Personal Information is no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) you withdraw your consent and there are no other legal grounds for the processing; (c) you exercise your right to object (see below) and there are no compelling legitimate grounds for the processing; (d) the Personal Information have been unlawfully processed; or (e) the Personal Information have to be erased for compliance with a legal obligation applicable to Us.
- Right to restriction of processing (i.e., data will be blocked from normal processing but not erased) where: (a) you contest the accuracy of the Personal Information, for a period enabling Us to verify the accuracy; (b) the processing is unlawful and you oppose the erasure of the Personal Information and requests the restriction of their use instead; (c) We no longer need the Personal Information for the purposes of the processing but they are required by you for the establishment, exercise or defence of legal claims; (d) you exercise your right to object (see below) pending the verification whether Our legitimate grounds override those of you.
- Where processing is based on your consent, the right to withdraw consent at any time, without affecting the lawfulness of the processing prior to such withdrawal. Please note that even after you have chosen to withdraw your consent, We may be able to continue to process your Personal Information in some limited circumstances if We can base such processing on another valid legal basis.
- Where processing is based on your consent, or on a contract, the right to data portability, i.e. the right to obtain a copy of the data concerning you in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from Us.
- Right to object to the processing of Personal Information based on Our legitimate interests, provided there are no compelling legitimate grounds for the processing that would override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Please note that in certain situations, and subject to applicable law, We may not be able or obliged to comply with all your requests, for example comply with a deletion request relating to information We are required by law to keep or have a compelling legitimate interest in keeping.
We may charge you a reasonable fee in case you request additional copies of your Personal Information or make excessive requests. If We are unable to honour your request, or before We charge a fee, We will expressly inform you. In so far as practicable and required under law, We will notify third parties with whom We have shared your Personal Information of any request for correction, deletion, and/or restriction to the processing of your Personal Information. Please note that We cannot guarantee third parties will follow up on Our notification and We encourage you to contact those third parties directly.
Click here to submit your privacy rights request: www.assurant.com/dataprotection/eu. You can also contact Us by any other means or by using the contact detail set out below.
Automated decision-making and profiling
We usually use automated decision-making tools when We make direct decisions about the policyholder (e.g. in certain compensation claims management processes). Whenever this is the case, you will be given additional information about automated decision-making processes before, or on the date We want to make decisions in this way. You have the right to obtain human intervention to challenge the decision, please see 'Your Rights and Choices' section above.
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 product or 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.
How to Contact Us
Click here to submit your privacy request: www.assurant.com/dataprotection/eu .
For general queries, please contact Our Customer Relations Team by emailing: [email protected]
For data protection queries, please contact Us by email at [email protected] or by writing to Us: The Warranty Group The Aspen Building Vantage Point Business Village, Mitcheldean GL17 0AF, United Kingdom
You may address a complaint or question concerning the processing of your personal information at the above-mentioned contact details. You may also lodge a complaint with your local data protection authority in the country where you live, work, or where you consider the problem has occurred.
Effective date: May 2022