AVIVA BRAND WEBSITE THIRD PARTY ACCESS PRIVACY POLICY

INTRODUCTION  

Welcome to the Aviva privacy notice for the Brand Website.

Aviva respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our Brand website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

1.  IMPORTANT INFORMATION AND WHO WE ARE  

PURPOSE OF THIS PRIVACY NOTICE  

This privacy notice aims to give you information on how Aviva collects and processes your personal data through your use of the Brand Website, including any data you may provide through the Brand Website when you sign up to access the Brand Website. Capitalised terms in this Privacy notice have the same meanings as the defined terms in the Aviva Brand Website Terms and Conditions unless stated otherwise.

The Brand Website is to allow third parties to use the Aviva Name and/or Logo for the reasons specified in the Terms and Conditions.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

 

CONTROLLER

Aviva is made up of different legal entities, details of which can be found on the main Aviva website at www.aviva.com. This privacy notice is issued on behalf of the Aviva group of companies so when we mention ”Aviva”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Aviva Group responsible for processing your data. Aviva PLC is the controller and responsible for the Brand Website.

The Aviva Group brand team are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact them using the details set out below.

 

CONTACT DETAILS

Our full details are: Aviva PLC (company number 02468686), registered office: St Helen’s, 1 Undershaft, London, EC3P 3DQ. If you have any questions in relation to this Privacy Policy, you can contact us as follows:

Address: The Aviva Group Brand Team St Helen’s, 1 Undershaft, London, EC3P 3DQ.

Email us at: brandclinic@aviva.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES  

This version was last updated in June 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

2.  THE DATA WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

       Identity Data and Contact Data includes your email address, and therefore maybe your first and last name.

       Technical Data includes your login data.

       Profile Data includes your username the date and time each time you access the Brand Website, and the login page that you used to gain access from

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

 3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect data from and about you including through:

       Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you apply to gain access to the Aviva Brand Website

 

4.  HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

       Where we need to perform the contract, we are about to enter into or have entered into with you.

       Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

       Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data unless we need to use it for a new purpose not compatible with the original purpose.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

you supply your email to access the Brand site

(a) Identity

(b) Contact

Performance of a contract

 

To process and provide you with access to the Aviva Name and/or Logo and how you can use them.

(a) Identity

(b) Contact

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

To manage our relationship with you which will include notifying you about changes to our terms and conditions or privacy policy

(a) Identity

(b) Contact

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

To administer and protect our business and the Aviva Brand Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

COOKIES  

The Brand Website does not use cookies.

 

CHANGE OF PURPOSE  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

       Internal Third Parties – Aviva staff who administer and otherwise operate the Brand Website.

       External Third Parties - NTT Europe Limited who host the Brand Website and store your personal data but cannot access the data. Bright Interactive Limited who provide technical support for the Brand Website and may access personal data when performing support activities, however, they can only gain access to the system with our consent.

       Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6.  INTERNATIONAL TRANSFERS  

We do not transfer your personal data outside the European Economic Area (EEA).

 

7.  DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8.  DATA RETENTION  

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your personal information allowing access to the Brand Website is for a single use/entrance to the site. You will have to enter the personal information again to gain access each time. We will retain your personal data for 24 months (the maximum time you may use the logo for) and we will then delete your personal data after a further 12 months.

 

9.  YOUR LEGAL RIGHTS  

You have various rights in relation to your personal information, including the right to request access your personal information, correct any mistakes on our records, erase or restrict records where they are no longer required, object to use of personal information based on legitimate business interests, ask not to be subject to automated decision making if the decision produces legal or other significant effects on you, and data portability. For more details in relation to your rights, including how to exercise them, please see our full privacy policy at www.aviva.com or contact us.

 

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.