Privacy notice

REVITI LIMITED CONSUMER PRIVACY NOTICE

Reviti Limited ("reviti" or "we") take privacy seriously. This notice tells you who we are, what information we collect about you, and what we do with it. In some sections, you can click “find out more” for further information. Please take a few minutes to read this notice and show it to anyone else connected to your policy.

Please also read our terms of use and, where you have purchased a policy from us and our partners, the terms and conditions of the policy you have purchased. They provide more information about the way we do business and any restrictions on eligibility that may apply.

Who are we?

We trade under the name reviti and are an appointed representative of Resolution Compliance Limited which is authorised and regulated by the Financial Conduct Authority (FRN:574048). reviti is the data controller of any data you provide to reviti or is otherwise collected through this website. This means that we determine the purposes and means of processing the data you provide us.

If you decide to purchase a policy through this website then your data will be shared with Scottish Friendly Assurance Society Limited ("Scottish Friendly") for the purpose of underwriting your policy. They need your data to consider your application, administer your policy and to handle any claims made on your policy. Scottish Friendly will also be a data controller in respect of any data we provide to them for those purposes as well as any additional data they may need to collect about you. Please refer to Scottish Friendly's privacy policy for further information about how and why they process your data to underwrite and administer your policy.

If you have any questions about how we process your personal data, please contact us using the details found at the bottom of this notice.

How do we collect information about you?

We may collect information about you in various ways.

  • Information you provide us. You may provide us with information directly (for example, filling in a form, emailing or calling us). This will be how most of the data about you that we process is collected. You will be asked to fill out forms during the quote and application process. We will not be able to provide you with a quote or inform you of an offer from Scottish Friendly unless you answer the mandatory questions.
  • We collect personal information when you:
    • Obtain a quote.
    • Apply for a policy.
    • Ask us a question.
    • Change your cover.
    • Update how we contact you with marketing.
    • Make a complaint.
    • Change ownership of a policy (for example, putting it in trust).
    • Take part in market research (for example, satisfaction surveys).
  • We may collect information automatically.
    • If you visit our website it automatically collects some information about you and your visit, including the internet protocol (IP) address used to connect your device to the internet and some other information such as your browser type and version and the pages on the site that you visit.
    • Our website may download "cookies" to your device. The cookies we use and their purposes are described in our cookie notice.
    • If you exchange emails, telephone conversations or other electronic communications with us then our information technology systems will record details of those conversations, sometimes including their content.
    • Our premises may have closed circuit TV systems for security and safety purposes. These may record you if you visit our premises.
  • We may acquire information from third parties. This includes:
    • Your doctor or other relevant medical attendants.
    • Fraud prevention, enforcement or government agencies used to prevent or detect fraud or provide details to us about criminal convictions or offences.
    • HM Treasury and other authorities in relation to regulatory issues.
    • Publicly-available sources. For example, information on social media platforms such as Facebook and Twitter.
    • Any price comparison website that you have used to find out about our policies.

What about information we collect from you about other people?

Occasionally we may need you to provide us with information about other people (for example, where we need to ask questions about the health of direct family members). Where you provide us with information relating to another person, you should make that person aware of this privacy policy and ask them to read it. For the purposes of this privacy policy, any references to your personal information should be interpreted as also including information you provide us about others.

For what purposes do we use information about you, and on what legal basis?

In this section, we describe the purposes for which we use personal information.

  • Providing you with the service you have requested. We process your data to provide you with the service you have requested or otherwise engaged us in respect of (for example, to provide a quote, submit an application you have completed, trigger a premium adjustment, or put you in contact with Scottish Friendly regarding a claim or a complaint).
  • Automated decision making. We need your personal information when you apply so Scottish Friendly can decide whether to offer you a policy and, if so, on what terms. An automated underwriting engine is used as part of this process. The engine takes account of the information you have provided (including your age, whether you smoke, your answers to our other questions) along with the amount of cover you wish to obtain. We’ll make clear to you in the application for each policy whether automated underwriting is used. Please see below ("what rights and options do I have?") to find out more about your rights when automated decision-making processes are used.
  • In relation to your policy. Throughout the life of a policy, we will hold your personal information to enable us to administer the policy. We may also use the information to help us understand you as a customer and ensure that our products are appropriately priced.
  • Business and operational reasons. We process your information to otherwise operate, manage, develop and promote our business. We also process your information to operate, administer and improve our website, premises and other aspects of the way in which we conduct our operations.
  • Better understanding our customers. We process your data to better understand our customers and offer them products and services to accommodate their needs and requirements.
  • Comply with our legal and regulatory obligations and to defend legal claims. We may need to process your personal information to comply with our legal and regulatory obligations and to defend ourselves against legal claims, for example, to carry out sanctions, fraud and money laundering checks.
  • To keep you updated about the policy. We will use your personal data to keep you updated about the policy and comply with our regulatory obligation to inform you about benefits you may be eligible for.
  • Direct marketing. When you fill out your application we will ask you whether you would like to receive marketing material from us. Where you let us know you would like to receive this material we will use your details in order to send you such information. If you tell us that you do not want to receive marketing information we will not use your information for marketing reasons. We will still need to contact you from time to time for the purposes of servicing your policy. You can update your marketing preferences at any time by visiting our website and updating your preferences using the link provided. If we send you marketing emails you can also unsubscribe by clicking on the unsubscribe link or by contacting us.
  • Marketing and research. We may anonymise your personal information to process it for marketing and consumer research purposes.
  • Other. For other purposes that we notify you of, or will be clear from the context, at the point information about you is first collected.

Given the above purposes for which we use personal information, the legal basis for our use of information about you is one of the following:

  • compliance with a legal obligation to which we are subject;
  • the performance of a contract to which you are a party; or
  • a legitimate business interest that is not overridden by your own interests in relation to that data.

In any other circumstances we will always ask for your consent before we process the information. This will be clear from the context.

In some instances, we may use information about you in ways that are not described above. Where this is the case we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.

If you are uncertain as to our need for information that we request from you, or have concerns relating to the basis for processing we are relying on, then please contact us (see below) with your query.

Do you process my sensitive personal information?

Yes, you will need to provide "special category" personal information to enable us to provide you with your quote or process your application for insurance. Special category personal data is afforded additional protection by data protection law. This data includes information about your health, including whether you are a smoker, for example, as well as information relating to your lifestyle and your family health history.

Unless we inform you otherwise, you should assume that we process this data for the purposes of arranging, underwriting or administering an insurance contract. For this reason, we do not require your consent. We may also retain a copy of any such information in order to comply with legal or regulatory obligations.

Who do we share your information with, and for what purposes?

We may share information about you with:

  • Other companies within our group.
  • Resolution Compliance Limited and Scottish Friendly as well as Scottish Friendly's reinsurers for the purpose of arranging, underwriting and administering the policy.
  • To service providers who host our websites or other information technology systems or otherwise hold or process your information on our behalf, under strict conditions of confidentiality, data privacy and security.
  • Carefully selected partners (in areas connected with our insurance products) so that they can contact you with offers that they think may interest you, in accordance with your marketing preferences and only with your consent where required.
  • To a person who takes over our business and assets, or relevant parts of them.
  • To our professional advisers.
  • In exceptional circumstances:
    • Regulators (e.g. the Financial Conduct Authority), government (e.g. HMRC) and law enforcement or fraud prevention agencies, as well as our professional advisers.
    • To competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in the applicable country or territory.

Where might information about you be sent?

When using information as described in this notice, information about you may be transferred either within or outside the United Kingdom where it was collected, including to a country or territory that may not have equivalent data protection standards. In all cases, the transfer will be:

  • on the basis of a European Commission adequacy decision (or equivalent decision in the UK);
  • subject to appropriate safeguards, for example the EU Model Contracts; or
  • necessary to discharge obligations under a contract between you and us (or the implementation of pre-contractual measures taken at your request) or for the conclusion or performance of a contract concluded in your interest between us and a third party, such as in relation to travel arrangements.

In all cases, appropriate security measures for the protection of personal information will be applied in those countries or territories, in accordance with applicable data protection laws.

How do we protect information about you?

We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, misuse, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with strict data privacy and security requirements. 

How long will information about you be kept?

We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete or anonymise it. The period will vary depending on the purposes for which the information was collected. Note that in some circumstances, you have the right to request us to delete or anonymise the information. Also, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes.

Where you have taken out a policy with us we will generally keep your information for a period of seven years following a claim or the end of your policy in line with the insurers policy, unless there is a requirement for us to retain the information (for example, a legal requirement, or where there are ongoing claims relating to your policy).

Where you have obtained a quote but not purchased a policy we will generally keep your information for a period of 6 months before deleting.

What rights and options do you have?

You may have some or all of the following rights in respect of information about you that we hold:

  • request us to give you access to it;
  • request us to rectify it, update it, or erase it;
  • request us to restrict our using it, in certain circumstances;
  • challenge a decision that has been made using automated decision making or otherwise request human intervention in an automated process;
  • object to our using it, in certain circumstances;
  • withdraw your consent to our using it;
  • data portability, in certain circumstances;
  • opt out from our using it for direct marketing; and
  • lodge a complaint with the supervisory authority.

We offer you easy ways to exercise these rights, such as “unsubscribe” links, or giving you a contact address, in messages you receive.

find out more…

Right in respect of the information about you that we hold, with further detail

(note: certain legal limits to all these rights apply)

  • To request us to give you access to it
    • This is confirmation of:
      • whether or not we process information about you;
      • our name and contact details;
      • the purpose of the processing;
      • the categories of information concerned;
      • the categories of persons with whom we share the information and, where any person is outside the EEA and does not benefit from a European Commission adequacy decision or equivalent UK decision, the appropriate safeguards for protecting the information;
      • (if we have it) the source of the information, if we did not collect it from you;
      • the existence of automated decision-making, including profiling, that produces legal effects concerning you, or significantly affects you in a similar way, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for you; and
      • the criteria for determining the period for which we will store the information.

On your request we will provide you with a copy of the information about you that we use (provided this does not affect the rights and freedoms of others).

  • To request us to rectify or update it
    • This applies if the information we hold is inaccurate or incomplete.
  • To request us to erase it
    • This applies if:
      • the information we hold is no longer necessary in relation to the purposes for which we use it;
      • we use the information on the basis of your consent and you withdraw your consent;
      • we use the information on the basis of legitimate interest and we find that, following your objection, we do not have an overriding interest in continuing to use it;
      • the information was unlawfully obtained or used; or
      • to comply with a legal obligation
  • To request us to restrict our processing of it
    • This right applies, temporarily while we look into your case, if you:
      • contest the accuracy of the information we use; or
      • have objected to our using the information on the basis of legitimate interest (if you make use of your right in these cases, we will tell you before we use the information again).
    • This right applies also if: 
      • our use is unlawful and you oppose the erasure of the data; or
      • we no longer need the data, but you require it to establish a legal case.
  • To object to our processing it
    • You have two rights here:
      (i) if we use information about you for direct marketing: you can “opt out” (without the need to justify it) and we will comply with your request; and
      (ii) if we use the information about you on the basis of legitimate interest for purposes other than direct marketing, you can object to our using it for those purposes, giving an explanation of your particular situation, and we will consider your objection.
  • To withdraw your consent to our using it
    • This applies if the legal basis on which we use the information about you is consent based. These cases will be clear from the context.
  • To data portability
    • If:
      (i) you have provided data to us; and
      (ii) we use that data, by automated means and on the basis either of your consent, or on the basis of discharging our contractual obligations to you,

then you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else if it is technically feasible for us to do so. 

  • To lodge a complaint with the UK Information Commissioner

Who should you contact with questions?

If you have any questions, or wish to exercise any of your rights, you can find contact details for reviti here. Contact details will also be given in any communications that reviti sends you.

The UK’s data protection authority is the Information Commissioners Office. You have a right to contact them with any questions or concerns (please see contact details above). If reviti cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.

Changes to this notice

We may update this notice (and any supplemental privacy notice) from time to time. We will notify you of the changes where required by law to do so.

Last modified [04/01/2019].