ASSURANT

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 

Administrator 

• 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 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). 

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 obtained 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 obtained 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). 
• Consent. Where you have consented to the use of your personal information for the purpose We explain at the time. E.g. We place cookies and use similar technologies in accordance with Our Cookie Policy. You will always be able to withdraw your consent by contacting Us or using the mechanism described to you at the time that your consent was obtained. Please refer to Our Cookie Policy for more details. We may also use your information for marketing purposes based on your consent. This refers to marketing about the products and services provided by Our group of companies (which includes The Warranty Group Services (Isle of Man) Limited, TWG Services Limited, Assurant Europe Services B.V., London General Insurance Company Limited, Assurant Europe Insurance N.V. but you may tell Us at any time that you wish to stop receiving any such information by contacting Us via Our Customer Relations Team by emailing: [email protected] or by clicking on the “unsubscribe” link contained in such messages. 
• 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.
• Business partners: We share your name, contact information (email, postal address, and phone number), vehicle details, policy number and policy information with Our business partners, for audit and customer experience purposes.
• 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 Information is Processed

For individuals located in the UK, 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 UK and other parts of the world. Where personal information is transferred outside the UK to a country that is not subject to adequacy regulations, including to the US, it is adequately protected by standard data protection clauses, an UK extension of the EU-US Data Privacy Framework, an UK Binding Corporate Rules or other approved transfer mechanisms. To obtain a copy of the relevant transfer mechanism or additional information on such transfers, please address these requests to Us.

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.

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 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 the personal information We hold about you (Access)
• Right to have your personal information corrected (Rectification)
• Right to have your personal information deleted (Erasure)
• Right to request the restriction of the processing of your personal information (Restriction)
• Right to request the portability of your personal information when We base our processing on a contract or your consent (Data Portability).
• Right to object the use of your personal information when we base the processing on a contract or on Our legitimate interests (Objection)
• Right to withdraw your consent when we base the processing on your consent (Consent)

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.

If you wish to submit a privacy rights request, please click on the following link: www.assurant.com/dataprotection/eu.

If you have unresolved privacy concerns, and you are located in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

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 or concerns, 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

Effective date: March 6, 2024