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 tells 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 for our business partners, who we commission to carry out work for us or who we collaborate with, and in so doing need to use the Aviva Brand Assets.
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.
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 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.
Address: The Aviva Group Brand Team St Helen’s, 1 Undershaft, London, EC3P 3DQ.
Email us at: email@example.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 May 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.
The Brand Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Brand Website, we encourage you to read the privacy notice of every website you visit.
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 first and last name, the organisation you work for, your work email address and your country and region.
• Technical Data includes your internet protocol (IP) address and your login data.
• Profile Data includes your username and password, the name of your Aviva contact, your usage of the Brand Website as set out below, which emails we have sent to you, what you say you will use the Aviva Brand Assets for, the date you registered to use the Brand Website, your preferences, and feedback and survey responses.
• Usage Data includes information about how you use the Brand Website, whether you are accessing the Brand Website, what Aviva Brand Assets you search for and view, which Aviva Brand Assets you download from the Brand Website and the time you do so.
• Communications Data – your preferences in relation to email updates for system alerts and new content. Please note that we also send factual information emails to all users from time to time when we need to let you know about something that will impact your usage of the Brand Website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Brand Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, allowing access to the Brand Website). In this case, we may have to cancel or refuse access to the Brand Website but we will notify you if this is the case at the time.
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:
• create an account on the Brand Website;
• apply to gain access to the Brand Website;
• give us some feedback.
• Automated technologies or interactions. As you interact with the Brand Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns as indicated above.
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 other than in relation to whether you want to be sent system alerts and new content notifications by email. You have the right to withdraw consent to these updates at any time by Contacting us.
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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a site user
Performance of a contract
To process and provide you with access to the Aviva Brand Assets and strategy guidelines including:
(d) what Aviva Brand Assets you download or viewed
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how partners use the Aviva Brand Assets)
To administer and protect our business and the Brand Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(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
To deliver relevant website content
(e) and Communications
Necessary for our legitimate interests (to study how the Brand Website and Aviva Brand Assets are used, in order to develop and deliver content that’s popular or missing)
You can ask us to stop sending you system alerts and content notifications at any time by logging into the Brand Website and checking or unchecking relevant boxes to adjust your communication preferences or by Contacting us at any time.
Where you opt out of receiving these messages, this will not apply to personal data provided to us by registering and using the Brand Website where we need to communicate with you so that you are able to continue to use the Brand Website and the Aviva Brand Assets correctly.
Cookies are small text files which contain a small amount of information that is downloaded to your computer when you visit a website. When you visit the website again, or visit another website which recognises that cookie, your device is able to communicate with the website and the website can read the information held in that cookie.
You can block any cookies from any website by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, if you block all cookies you may not be able to access all or part of our Websites. You can also use your browser settings to delete cookies. For more information about how to disable cookies in your browser please visit www.allaboutcookies.org.
Tomcat Session Cookie
The Brand Website runs on a server in an application called 'Tomcat'. Tomcat places a temporary session cookie called JSESSIONID on your computer so that the Brand Website can maintain your user session as you navigate around the Brand Website. This cookie contains no personal information - all it stores is a numeric ID that has meaning only to Tomcat for the duration of your session. The cookie has no use after the end of your session on Brand Website. Note that this cookie is essential to the operation of the Brand Website.
'Remember Me' Cookie
The Brand Website has a 'Remember Me?' checkbox on the login page. If you tick it, then Asset Bank will place a cookie called 'AssetBankUserAuth' on your computer. This cookie will be used the next time you visit the Brand Website so that you can be identified and logged in automatically. The only information this cookie contains is an encrypted value representing your Brand Website numeric user ID (not your username).
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 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 account allowing access to the Brand Website will automatically expire after 12 months (unless you are an employee of Aviva Group), you can then apply to extend access for further 12 months periods. We will retain your personal data while you still have access to the Brand Website. If your account has expired or been suspended for a period of 24 months we will then delete your personal data and a new application and submission of personal data will be needed for you to regain access to the Brand Website.
9. YOUR LEGAL RIGHTS
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.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
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 a number of requests. In this case, we will notify you and keep you updated.