Who we are
When you purchase one of the other products or services we distribute, you will be purchasing from one of our carefully selected third party product providers. We will share the information that we collect from you with these providers to enable them to set up and administer your policy. For detailed information on how they may use your personal information, you will need to refer to their individual privacy policies, details of which can be found at the end of this policy.
If you have requested a quote or started (but not completed) the quotation process, we will share your information with our telephony providers who will contact you to support you with your enquiry. Otherwise, we will never share your information with third parties, including our product providers, for marketing purposes.
For certain products and services, we may send you service communications by post, email, texts and other electronic means. These will be administrative messages linked to your policy and reminding you of any benefits.
If you have made an enquiry, such as asking for a quote or starting the quotation process, we will also share your personal information with our telephony providers. This will enable them to respond to, or support you with your enquiry in a timely and effective manner.
What information we collect
Firstly, we try not to ask you for personal information that we don’t need. The personal information we do collect about you will vary depending on the product or service, and whether you are enquiring about a product or have previously purchased through us.
We may also request additional information about you from a third party such as customer research companies or data cleansing agencies as an example. We may also purchase basic personal details of prospective customers for marketing purposes.
|What personal information we may collect||Examples||When we collect this sort personal information|
|Basic personal details||
|Proof of identity||
|Information from devices you use||
|Preferences and interests||
How we use your information
There are many reasons why we may use your information, from simply replying to a request for a brochure, to carrying out obligations we have to prevent and detect fraud. How we use your personal information will again depend on the product or service, and whether you are enquiring, purchasing or have previously purchased a product or service.
|How we use your personal information||Examples|
|Process your policy||
|Meet legal and regulatory obligations||
|Improve our business||
Legal basis for using your information
We will only collect, use and share your information where we have a valid reason to do so under data protection legislation. We have 4 main reasons for using your information:
1. Contract – we may need to process your information to fulfil contractual obligations, or to respond to a request for information before entering into a contract (for example, providing a quote)
2. Legal obligation – we may need certain information from you to meet our legal and regulatory obligations; for example, proof of identity to check against fraud.
3. Our business interests – we may use your information to meet our legitimate business interests. When we process personal information to meet our legitimate business interests we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
Our business interests include:
- to follow up on a product quote or enquiry
- to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers
- to better understand how people interact with our website
- to provide postal and/or telephony marketing which we think will be of interest to you (see Marketing and Profiling section for more information)
- to determine the effectiveness of promotional campaigns and advertising
4. Consent – there may be occasions where we need to obtain your consent in order to receive future marketing from us. If we ask for your consent to process your personal information you have the right to withdraw your consent at any time. Please see the section on ‘Your rights’ for further information.
Marketing and profiling
For certain products and services, we may send you service communications by post, email, texts and other electronic means. These will be administrative messages linked to your policy and reminding you of any benefits. You will not be able to opt-out of receiving these essential service communications.
From time to time, we may send you marketing material which we believe will be of interest to you. We may market by post and telephone, and we will only send you marketing messages by email, texts and other electronic means if we have your permission. If you do not want to receive marketing from us please contact us using the details at the end of this notice
The way we use your data for marketing purposes will differ depending on whether you are enquiring, an existing customer, or a previous customer.
- If you have enquired about a product but not purchased, we will only follow up on this enquiry for a maximum of two years
- If you are an existing customer, you may receive service related communications for as long as you hold your policy. You may also receive marketing messages about our other products and services until your policy ends, unless you have opted-out of receiving marketing messages from us
- If you have cancelled your policy with us, we will stop sending you service messages and will only send you marketing communications related to the product you held for a maximum of one year after you cancelled, unless you have opted-out of receiving marketing from us
We group and organise our customer information to help us develop offers, products and services to provide you with the best customer experience; this is known as profiling. We use services and information provided by third parties to do this; for example, we may profile customers to see if they prefer using our website for information about their products. If they do, we would contact those customers to let them know about any new online services we are offering. We do not use profiling to make decisions about you which have legal or other significant effects.
If you do not want us to profile you please contact us using the details found at the end of this notice.
How long do we keep your information?
We will keep your information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
- Maintain business records for analysis and/or audit purposes
- Comply with record retention requirements under the law
- Defend or bring any existing or potential legal claims
- Deal with any complaints regarding our products or services
- Send you marketing information in accordance with your marketing preferences and as outlined in the section above
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
If you require additional information on our data retention standards please contact our Data Protection Officer using the details at the end of this notice.
Who do we share your information with
|We share your information with||Why we share it|
|Product providers||We distribute several financial products that are manufactured by different product providers. We will share your information with these providers to enable them to set up and administer your policy effectively. To understand how they may use your personal information, you will need to refer to their individual privacy policies|
|Telephony providers||If you have made a query, we will also share your personal information with our telephony providers. This will enable them to respond to your original query in a timely and effective manner.|
|Service providers||We use third party companies that provide services to us so we can help process your policy and deliver a service to you; for example, customer service providers or IT system companies that hold or analyse your information and carry out searches that help us trace you if we have lost touch.|
|Marketing service providers||We use third party marketing companies to help us make sure we are talking to the right people about the right products; for example, data agencies who can provide us with information to better inform how best to contact you, or build profiles of new audiences to contact based on our existing customer data|
|Anyone you ask us to share your information with||If you ask us to share your information we will. For example, with a trustee, professional adviser, etc.|
|Regulatory and government industry bodies such as:
- Fraud Prevention Organizations
- Law enforcement bodies
- Courts and those involved in legal process
|To comply with our legal and regulatory obligations which may include best practice|
|Customer research partners||We conduct customer research to understand what our customers think about the products and services we provide.
Sometimes we use third parties to undertake the research on our behalf. If you are contacted for research purposes we will be clear about the purposes of the research, how any information you provide will be used, who will have access to it and how long it will be kept. We will obtain your consent before we start the research.
|Professional advisers||We use professional advisers to provide services to us, for example legal advice, accountancy services and consultancy services.|
|Anyone in the future who may buy or merge with our business.||If we merge with another company or if we are sold then we will need to share your information with the other party.|
What if you don’t provide personal information?
If you do not provide certain information we may not be able to provide our service to you; for example, if you don’t provide the information requested on an application form we may not be able to process your application. We will try to make clear what information we really need and what information would help us which is not essential.
Your rights to accessing and correcting your information
We have explained below your rights, but to keep things simple we have not included all the circumstances or conditions which apply to them. If you would like to exercise these rights please contact us via the details provided at the end of this notice. If for any reason the right is limited or doesn’t apply we will explain to you why this is the case.
Stop using my information – if you don’t want us to use your information for our business interests you can ask us to stop and we will do so unless there is an important reason why we need to continue using it.
Stop marketing – you can ask us not to send you marketing messages.
Access - you have the right to ask for a copy of the information that we hold about you and this will usually be provided free of charge. For your security, we will take reasonable steps to confirm your identity before providing you with any personal information we may hold about you.
Transfers – you can request that we transfer information we hold about you to you or a third party in electronic form.
Remove my information – in certain circumstances you can ask us to stop using or holding your information, or ask us to restrict our use of the information. If we can delete your information we will, but sometimes we have to maintain records for legal reasons. If we cannot comply with your request then we will contact you and explain why.
Consent – if you have given consent for us to use your information then you have the right to withdraw your consent at any time. The Phoenix Data Protection Officer, who may be contacted at the address and on the telephone number below, will be able to explain to you the consequences of withdrawing your consent.
How to update your information
It is important that the information we hold about you is accurate and up to date. Please contact us via the details at the end of this notice if your information changes, or you believe the information we hold about you is incorrect.
Where do we send your information?
We operate primarily in the United Kingdom. However, sometimes the information that we collect from you may be viewed from, transferred to, or stored, outside the European Economic Area (EEA).
We ensure that we put in place appropriate safeguards when we allow your information to be processed outside the EEA. Please contact our Data Protection Officer using the details below if you would like more information on the appropriate safeguards we have in place.
Links to 3rd party websites
SunLife Limited is the controller responsible of the personal information we collect and process.
SunLife Data Protection Officer contact details
If you have any questions, would like to raise a complaint about our use of your information or would like a copy of the information we hold about you, please write to:
SunLife Data Protection Officer
1 Wythall Green Way
How to complain to the ICO
You have the right to complain to the Information Commissioner whose contact details are:
Information Commissioner's Office
Please call us on 0800 904 7678 to update contact details or marketing preferences.
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