Information That We Collect

As an Insurance Intermediary we need to collect many categories of Personal data (about you and other parties) for the purposes set out in this notice. The types of data we collect will depend on the product or service you are availing of. While subject to change over time the following list provides an indicative list of the different types of data we may collect:

Name, address (including proof of address), age, date of birth, email address, contact number, gender, marital status and bank account details or credit/debit card details.

Individual Details:

We may collect your Personal Data from a number of different sources such as but not limited to:

You, joint policy holder, any representative nominated by you to act on your behalf such as a family member or legal representative, your insurance company, Anti-fraud databases, sanctions lists, court judgements and other databases, other insurance market participants, law enforcement agencies such as An Garda Síochána & Criminal Assets Bureau, publicly available information including social media websites, electoral register, online content, TV, radio, and other media content, your device when you access and use our website. In the event of a claim, third parties including the other party to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, solicitors, insurers and claims handlers.

We may use your personal information to identify you as a customer, for the provision and administration of insurance products and related services. We may also use your information for marketing purposes where you have given us your consent to do so. Should you be unable to provide us with the required personal data, we will be unable to provide you with insurance. By going ahead with a quotation or policy or by giving us personal information you will be explicitly agreeing to us, the Underwriter/Insurer and other persons described in this notice processing it for all relevant purposes.

If you give us information about someone else, we will use it in the ways described in this Privacy Policy. Before you disclose information to us about another person, you should be sure that you have their agreement to do so. You should also show them this policy. You need to ensure they confirm that they know you are sharing their personal information with us for the purposes described in this Privacy Policy.

Phone calls may be recorded for quality and training purposes (including verification).

How We Use Your Personal Data

The main purposes for which we use your personal information is to provide a quote, verify the accuracy of the information we receive, setup, administer and manage your policy along with for market research, analytics and if you consent marketing purposes. We take your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law or due to contractual obligations. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.

We may share your personal information with the following:

• Government, Statutory and Regulatory Bodies, such as Data Protection Commission, the Revenue Commissioners, the Central Bank of Ireland and the Financial Services & Pension Ombudsman;

• Law Enforcement Agencies such as An Garda Síochána & The Criminal Assets Bureau.

• We may share your personal data with or seek personal data from your comparison company (if applicable), travel agent or insurance broker (if applicable) or anyone authorised by you to act on your behalf.

• If you have purchased an An Post Insurance Pet Insurance policy through us we may share your personal data with An Post Insurance.

• We may share personal data with or seek personal information from the Underwriter/Insurer and/or their handling agent (Insurance Provider), the claims provider, repairers and other claims handling agents, emergency assistance team, medical practitioners, engineers and legal practitioners.

• We may share your personal information with our employees, agents and contractors including companies that provide services in relation to telecommunications and postage, data storage, document production and destruction, IT and IT security, fraud detection, making and receiving payments, data analysis and management information, credit checking, risk analysis, complaints handling, marketing and market research.

• We may share your data with distributors for the purpose of delivering promotional items.

• We may share your personal information with any party you have given us permission to speak to or in certain circumstances other people insured under your policy of insurance and other people or companies associated with you.

• We may share your information with Banks to assist in the detection and prevention of fraud.

If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person who is able to provide it concerning:

• the existence of the insurance contract,

• who the insurer is,

• the terms of the contract, and

• whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract.

All telephone calls are recorded and monitored for quality and reference purposes.

Contacting you

We may contact you about an enquiry you have made or a quotation you have received, regarding the administration of your insurance policy, to tell you about any important changes to your insurance policy, to provide you with renewal terms on an existing policy, to conduct a customer survey on the products and services we provide or to conduct market research, to handle any customer service queries or complaints or where there is another genuine reason for doing so.

The following section details the purpose for which we process your personal information and the legal basis for which we do this.

Purpose/Activity

To provide you with a quote for an insurance product and to provide you with insurance cover if you decide to purchase a product.

To provide a customer service follow up to the quotation provided online

To verify your identity or the identity of your authorised representative

To respond to your queries and to provide you with the information you request from us in relation to our services.

To administer your insurance policy, make any midterm adjustments, answer any queries you may have, provide updates, process a cancellation or process a renewal.

To manage payments, fees and charges in respect of insurance premiums, and to collect and recover money owed to us.

To manage our relationship with you, including notifying you about changes to the Services.

To manage and assist you with the Insurance Claims process

Recording telephone calls (for quality, training and verification purposes)

To provide you with marketing communication about other services we feel may interest you.

To carry out statistical analysis including internal or market level research exercises

To allow you to participate in competitions, prize draws and other promotions.

To prevent detect and report fraud, money laundering and other offences. To assist An Garda Siochána or any other authorised body with investigations.

To manage and investigate any complaints, feedback and queries

To comply with laws, regulations and regulatory requirements

Transferring books of business, company sales and reorganisations

To establish and defend legal rights

To manage our business operations and IT infrastructure

To use data analytics to improve or optimise our Site, marketing, customer relationships and experiences.

Withdraw Consent / Unsubscribe / Opt-Outs

Where you have provided consent, this can be withdrawn at any time by emailing us at dataprotection@yesinsurance.ie by selecting the unsubscribing option in any marketing correspondence you receive from us.

Change of Use

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 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 this Policy, where this is required or permitted by law.

Links to Third Party Websites

If we provide a link on any of our websites to a third-party website, the content, accuracy and function of such websites are outside of our control and we cannot accept responsibility for same. Any dealings you have with such third-party websites shall be on the terms and conditions of that website operator. If you have a concern regarding the way your personal information will be used on other sites, then you are advised to contact the company concerned to request a copy of their privacy policy if not available to you via their website.

Data Subject Rights

The following is a list of your rights in connection with your Personal Data (Personal Information) under Data Protection legislation:

• You have the right to request a copy of your personal data that we hold on you

• To have any incorrect personal data we hold on you corrected

• You have the right to withdraw your consent for the processing of your personal data

• You have the right to object to the processing of your personal data

• To request to have your personal data erased or the processing of your data restricted

• You have the right to data portability for insurance purposes

• You also have the right to lodge a complaint with the Data Protection Commissioner.

Please note that withdrawing consent and requests for restriction/erasure or objection to the processing of your personal data may affect our ability to provide you with insurance. Some of the above rights are subject to limitations in order for us to comply with our regulatory obligations.

The withdrawal of consent will not affect the lawfulness of processing based on the consent before its withdrawal.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information / Third Party Sharing

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice, where there is a legal requirement or where we are obliged to by contractual agreement. We may use third party companies to assist in the provision of the services we provide or the general running of our business, companies such as (but not limited to) Global Payments to provide a secure payment facility, Everything I.T to assist in the general running and security of our systems, Aircall for provision of our telephone service and Intercom for our email and web chat services. The third party companies we use are not limited to those listed above; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

Up to date Information

In order for us to keep your information accurate and up to date, please contact us if any of your details change.

Safeguarding Measures

We take your privacy seriously and take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including but not limited to digital certificates, data encryption, firewalls and anti-virus/malware.

Cookie Notice

For further information on our use of cookies please refer to our separate Cookies Policy.

Transfers Outside the EU

Personal Information may be accessed/hosted/stored in countries outside of the European Union by us and some of the service providers we use. Where this is the case, we will take certain steps to ensure that the necessary level of protection for your information is used and are complying with the relevant data protection laws. These steps can include at least one of the follow safeguards: the provision of EC approved Model/Standard Contractual Clauses or ensuring that the privacy laws of the non-EEA country give the same protection as the EEA. Certain Underwriters/Insurers that are also a controller with may also access/host/store data outside of the European Union.

Automated Decision-Making Including Profiling

Automated individual decision making, including profiling, can take place when you request a quote through one of our websites. The insurance providers we provide quotes on behalf of carry out this automated individual decision making. Using the information provided to us in your online quote form we run your personal data through algorithms and internal models either agreed with or set by each of the insurance providers to determine your risk profile and calculate your insurance premium. For example, some factors that insurance providers would use for a pet insurance policy are your address, the breed, age, sex and value of your pet, along with the policy type selected.

You have the right to request human intervention to express your interests and contest automated decisions. If for any reason you are not satisfied with the quote obtained via our website, please contact our office to discuss your quote. Our contact numbers are clearly set out during the sales process. For further information on individual insurance providers automated decision making processes, please refer to their privacy policy.

How Long We Keep Your Data / Data Retention

We only retain your data for as long as is necessary for the purposes of providing insurance products and related services to you and so as to comply with legal and regulatory requirements. Generally, we will keep information for the following periods:

Type of Information

Quote Information (where a policy has not been purchased)

However, in certain cases we may need to keep personal data longer than the above periods such as long running disputes. Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Queries and Complaints

If you are unhappy with the way we have handled your personal information or If you have any queries regarding this notice you can contact us at dataprotection@yesinsurance.ie

Alternatively, you have the right to lodge a complaint with the Data Protection Commissioner. Their contact details are as follows:

Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois

Telephone: +353 57 868 4800 / +353 (0) 761 104 800 or Lo Call: 1890 252 231

Email: info@dataprotection.ie