If you are a current or former Animal Friends customer or business partner, are purchasing our products, using our services, enquiring about a policy, making a claim or visiting any of our websites, then Animal Friends and the Insurer, Pinnacle Insurance Company Plc, are a ‘data controller’ of your personal data and this is our commitment about how we manage your personal information.

As a data controller, we are responsible for determining what data we collect from you, why we need it and how we will process it. 

We are part of the Pinnacle Pet Group (PPG) – a group of pet insurance and pet product & service companies owned by Pinnacle Pet Group Ltd and headquartered in the UK. Our group comprises the following organisations:-

• Animal Friends Insurance Services Ltd
• Pinnacle Insurance Company Plc
• Pinnacle Insurance Management Services Plc
• Pet Protect Ltd
• VioVet Ltd
• Agila Haustierversicherung AG
• Veterfina Verzekeringsmaatschappij. N.V
• Veterfina B.V.
• Tiergarant Versicherungsdienst GmbH
• HD Assurances
• CaptainVet SAS

Animal Friends Insurance Services Ltd and Pinnacle Insurance Company are registered data controllers with the UK Information Commissioner’s Office (ICO) under number Z6313845 and Z5272015, respectively. Our shared commitments to you are:

• We will keep your personal information private and safe.
• We will only use your personal information in ways we think you would reasonably expect, as outlined in this Privacy Notice.
• We will only give our staff access to your data where they need it to be able to carry out their duties.
• We will only share your personal information with other organisations for specific purposes and where your data is kept in accordance with this notice.
• We will only keep your personal information for as long as we need it to provide you with a service or product or to comply with law and regulation.
• We will consider your privacy before we make any changes to our processes or systems where the processing of your data is involved.
• We will keep you informed of any changes we make to the way we manage your data by updating this Privacy Notice or emailing you if there is a significant change.

Your responsibilities

• Read this Privacy Notice and revisit it when you have a query about our use of your personal information or if you haven’t read it in a while. Our processes will change as our business evolves and we will update this notice in line with those changes. If we make a material change to the way we process your personal information we will inform you directly.
• Read your terms of purchase or service, and your policy documents carefully as this contains important information about your product or service purchase; or insurance contract with us. Most of the personal data we hold about you is processed for the purpose of administering your purchase or your insurance contract.
• If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us, which is explained in the section ‘How and why we use your data’ below.
• You are responsible for your username and password for access to any customer or partner portal we provide - please keep them secret and safe!
• If you believe your privacy has been breached, please contact us immediately on data.protection@animalfriends.co.uk.

From the first moment you interact with Animal Friends, either because you are a business partner, customer, enquirer or you interact directly with us on our website or by visiting a price comparison website, we are collecting data. In some instances, this data is anonymised, and we are unable to identify you (for example, when you visit our website, we will use cookies to track how you interact with our site and navigate the pages so we can look at how to improve our website and make your experience better, but we won’t link this activity to the record that we hold for you). You will need to allow cookies to operate for us to undertake this type of tracking and you can block these cookies from operating entirely by using the cookie controls on our websites. For more information on the cookies that we employ, please read our Cookie Policy.

We also collect data about you from external sources for the purposes of verifying or enriching our data or product offering where this is required for your purchase of a pet product, a service or an insurance product:

• official public records (e.g. census data, electoral roll);
• our service providers, commercial partners, your current insurer (where there is a transfer of cover), co-insurers, corporate insurers and re-insurers;
• third parties such as fraud and crime prevention agencies (including national law enforcement and other insurance providers) or data brokers (in accordance with data protection legislation);
• websites and social media containing publicly available information;
• databases and information made public by you or third parties.

Types of data we collect:

• Contact details - your address, telephone number, email address
• Contact details of other persons who will act on your behalf and are named on your policy - please ensure you have their permission to do this.
• Identity details - your name, your postcode, date of birth
• Financial information - your bank account number, sort code, payment card details
• Data that identifies you - your IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version.
• Loyalty scheme and purchase history information from our brand partners.
• Call recordings (please note recordings are kept for a maximum of two years).
• Live Chat and Chatbot transcriptions (Chatbot transcriptions are only kept where you request an agent call back).
• Data on how you use our Websites/Mobile Apps - your activities and clicks as you travel through our websites or mobile applications, which captures the pages viewed, page response times, download errors, how long you stay on our websites and what you do on those pages.
• Data on how you interact with our direct marketing emails – when you open and click-through any of our email content.

Where necessary and subject to your explicit consent, we may collect the following special categories of data for the reasons stated below:

• Health data that is required to process a claim or help us administer your contract if adjustments are needed.

We do not collect or process any data relating to your racial or ethnic origin, political beliefs, religious or philosophical beliefs, trade union membership, your genetic data or sexual orientation, unless we have a legal obligation to do so.

What about children’s data?

Animal Friends online purchases for pet products and services and purchases of insurance products can only be bought by persons over the age of 18 and for most of our products we do not knowingly collect any personal data from any person under this age. Exceptions to this are: for the provision of a ‘Young Rider’ horse riding policy; or in relation to a public liability claim. Data of children aged under 16 will only be collected with the consent of their parent or guardian.

Data protection law means that we can only use your data for specific reasons and where we have a legal basis to do so. Here are the legal bases for our processing of your data and what each of them mean:

Legal basis: Contract

Processing your data is necessary for a contract you have with us, or where there are steps that need to be taken before the contract is entered into. Processing we undertake where this legal basis applies is as follows:-

Providing you with an insurance quote
Where you request an insurance quote from us, either via a price comparison website, a distribution partner or directly via our websites or through our Customer Service center. 

Providing you with an insurance policy
When you have received a quote and decide to buy an insurance policy with us, we will collect further information such as your payment details to activate your insurance policy.

Administering your insurance policy
Administrative tasks will include, but are not limited to, providing customer services, processing payments, calculating premiums, updating policy documents, amending owner, pet and bank /payment details.

Providing you with support services
Providing you with services to support your policy, as described in your policy documents such our online veterinary service, Joii.

When we communicate with you or answer your queries
We will process your name and other items required to verify your identity and we will maintain a history of your interactions with us in your customer record. 

When we process insurance claims
If you submit a claim, we will ask for information about your pet’s condition and the treatment they received. We may ask for receipts and treatment plan documentation. We may need a medical history for your pet to confirm that any condition is not pre-existing. We may talk directly to your vet (and any previous vets you have visited) to get further information where necessary. This information is used to assess claims in line with the terms and conditions of your insurance contract.

If you are a vet or veterinary staff submitting a claim, we will process your name and work contact details in the administration of the claim. 

When you buy a non-insurance pet product from us
If you purchase a product from us, either on our website or in our customer application we will process your data to collect your payment and provide you with the product you have purchased.

Legal basis: Legitimate interests

Processing your data is necessary for our legitimate interests or the legitimate interests of a third party.

These legitimate interests are only valid if they are not outweighed by your individual rights and interests so in each case, we will complete an assessment, known as a ‘balancing test’, to determine whether your interests override the legitimate interests gained by Animal Friends processing your data.

Processing we undertake where this legal basis applies is as follows:-

Customer services and managing complaints
Notifying you of any changes to our service; solving issues via live chat support, phone, or email and recording our interactions; providing you with a quote retrieval message by email; asking you for a review of our products or services; handling any queries about payments, discounts, and transactions.

Management information and business process and product improvement
We will use your data to improve the insurance products and services we offer, and to streamline and evolve the way that we manage our relationship with you. We create and develop statistical models and undertake analysis for research and development purposes, allowing us to improve how we manage risk and create new and alternative products and services. We also seek to offer more competitive pricing or better personalised products and services through this processing. 

Direct marketing and profiling purposes
We may engage direct marketing specialists to inform prospective customer of our products and services through postal campaigns. 

We will use your data to find other customers who are similar to you, for online advertising. We will also use your data with advertisers to stop serving our advertising to you online (e.g., advertising on your Facebook newsfeed). You can object to this processing and stop it at any time by changing your privacy settings in your social media accounts or by emailing: data.protection@animalfriends.co.uk.

Prevention and detection of fraud
We monitor transaction to identify those that do not meet normal routines or patterns. We may ask you to undertake fraud prevention checks at the point of sale. For example, a credit referencing check through a third party such as Experian. We also periodically check our back book through fraud prevention and credit referencing agencies to manage risk and prevent criminal activity. Where we have reason to believe a claim may be fraudulent or criminal activity has occurred, we may share relevant information with other insurance companies, fraud prevention and credit referencing agencies, and law enforcement as necessary. Where another insurance company or an authorised agency requests information in relation to fraud or criminal activity, we may provide that information. We retain fraud investigation files for up to 10 years to mitigate risk internally.

Managing our assets / Information security
We may process your data when we manage our IT assets as your data may be stored in physical devices. We have a robust information security framework to ensure our physical assets are protected.

Refer a Friend Scheme
If you refer a friend to us, then we will process your name and policy information to match your referral to your friend who has bought a policy with us so that we can provide you with the relevant reward.

Customer surveys, reviews, and competitions
We invite feedback from our customers via surveys or through reviews using such platforms as Google, TrustPilot or Rant & Rave so that we can look at how to improve our services. We also run competitions for our policy holders to reward loyalty and strengthen our relationship.

Recording customer calls
We record our sales and customer service calls so that we can review the calls our agents undertake to look at where improvements can be made. These call recordings may also provide a valuable audit if there is a query in relation to a sale or claim. Call recordings are retained for up to two years from the date of the call.

Anonymising and deleting your data
We anonymise personal data at the first opportunity as an important measure in our privacy approach. When the retention period for our quote or insurance customers is reached, we will permanently delete personal data so that it is irretrievable. 

Legal basis: Consent

You have given clear consent for Animal Friends to process your personal data for a specific purpose. You can withdraw your consent at any time.

Processing we undertake where this legal basis applies is as follows:-

Direct marketing purposes (with your consent)
Sending you emails and text messages about new features, products and services, and content. You can withdraw your consent for this at any time by clicking on the ‘Unsubscribe’ link in our emails or calling Customer Services via info@animalfriends.co.uk or by contacting us on 0344 557 0300.

When you interact with our Chat Bot and Live Chat
We will only collect any Chat Bot interactions when you provide your consent by giving our chatbot your contact details when requested to be transferred to a live chat agent. You can stop this collection by stopping the chatbot or live chat interaction at any time. 

Legal basis: Legal obligation

Processing your data is necessary to fulfil a legal obligation such as defending your, or our, legal rights, adhering to regulatory requirements, responding to a request from the UK or EU courts or law enforcement.

Processing we undertake where this legal basis applies is as follows:-

Sanctions screening
We must screen customers and suppliers against national sanctions lists to comply with anti-money laundering and international sanctions requirements.

Managing Data Subject Rights
If you make a request to exercise any of your rights under data protection law, we will process your data as is necessary to fulfil your request.

Defend and prosecuting a public liability claim or other legal challenge 
We will need to process the personal information in the relevant customer file in order to prepare a defence or response, e.g., to the Financial Ombudsman Service (FOS).

Information Security
We are required to ensure that your personal data is secured using appropriate technical measures. We regularly scan our systems to protect against unlawful access and may process personal data in this action.

Complaints
To comply with FCA requirements we retain full details of all complaints. Where you complain on social media or on a review website, whether privately or publicly, please be aware that we may be required to treat this under our complaints process in line with FCA requirements. If we can match a complaint made on social media or on a review website to a customer record based on information provided in that complaint, or which is publicly and obviously available on the site where you have complained, we may do so to provide a more personalised response.

Our legal basis for processing special category data

Where we collect and store your health data for the provision of insurance or for administering a public liability claim, we process this either with your explicit consent or based on a substantial public interest (for the provision of insurance for the protection against financial harm). We may also process your special category data for the establishment, exercise, or defence of legal claims when we are faced with any legal claims or where we pursue legal claims ourselves. 

We are committed to taking the necessary organisational and technical measures to protect your personal data when we process it and when we share it with third parties. We undertake that:

• All our employees are subject to confidentiality obligations to ensure the adequate protection of your personal data.
• We use appropriate security measures to ensure the confidentiality, integrity, and availability of your data, as well as certifying systems and services which are resilient and can restore data in the event of a data loss.
• Where possible, we aim to secure your personal data by lessening or removing personally identifying elements.
• We regularly evaluate the effectiveness of our technical and organisational measures to ensure continuous improvement in the security of processing personal data.

The personal data we collect is processed and stored in the UK or Europe. In some instances, we will employ other companies who will process your data, and, in every case, we will ensure that any other company that we transfer your data to is subject to the same level of data protection as we are. 

This means that where we may transfer or allow access to your information outside the UK or EEA (European Economic Area), we will take steps to ensure that your privacy rights continue to be protected to the same standard as required to comply with UK and EU regulation.

We will process your data for as long as is required to provide and administer your insurance quote, policy and any related claims or complaints, as well as complying with legal financial reporting requirements. This will typically mean that data is retained for a minimum of six years.

We hold anonymised data, where we have removed any of your identifying details, for a longer period so that we can look at trends across pet insurance, veterinary claims and the services and products we have provided over an extensive time. As this data is anonymised, it is no longer ‘personal’ data and not subject to this commitment.

Within Pinnacle Pet Group

We will share your data across our group companies, either where you have provided your consent for us to share your personal information for marketing purposes or if we have a legitimate interesting in sharing, such as sharing information to prevent and detect fraud and money laundering.

Our insurer
We share your data with our Insurer, Pinnacle Insurance Company PLC, who underwrite your policy and are part of the Pinnacle Pet Group.

Outside Pinnacle Pet Group

Veterinary practices and pet treatment providers
When you make a claim on your insurance policy, we will liaise directly with your current and previous veterinary practice to settle your claim as quickly as possible. We will often obtain pet medical history from your veterinary practices to confirm that there are no exclusions.

Price comparison websites and partners
If you are directed to Animal Friends from a price comparison or partner website and you buy a policy from us, we must inform that price comparison or partner website that you have bought a policy to pay them a commission fee. We will therefore share identifying details and premium information back to the price comparison website and brand partner for the administration of their fees. 

Our offshore claims processing team
We use an offshore claim processing team that enables us to ensure we can process claims in a more expedient and cost-efficient way which has a direct benefit to you as a customer in speeding up the claims process. Whilst your data is stored in the UK, it is being accessed by our claims processing team in India.

Review platforms
Customer feedback is very important to us so we will invite you to leave a review either on our Rant and Rave platform or via Trustpilot or Google. It is entirely optional for you to leave a review. Any feedback you give us is used to review our services and products to try and improve them or to recognise our staff for a job well done.

Marketing services providers
We undertake marketing and advertising to let relevant people know about our insurance products and our charitable giving. We will share your information with social media platforms, specialist marketing agencies and internet service providers who you already have a relationship with for two main purposes: firstly, to stop advertising for our insurance products featuring on your social media feeds if you already have an insurance policy with us, and secondly, to understand more about our customers so that we can extend our offers to other people who would be interested in our products and services. 

Fraud prevention specialists and agencies
Your personal information may be checked with and recorded by a fraud prevention specialists and agencies. If false or inaccurate information is provided and fraud is identified, details may be passed to the fraud prevention specialist or agency. This information will be accessed and used by Animal Friends, law enforcement agencies and other organisations to prevent fraud and money laundering. We use insurance industry databases such as the Claims and Underwriting Exchange where you make a claim so that we can check your claims history.

Other specialist third parties
We use third parties to host our data and our websites and applications and to provide support services. We also use third parties to undertake specialist tasks for us such as processing payments, undertaking direct marketing campaigns, maintaining data accuracy, managing public liability claims and keeping our IT systems secure.
When we do this, sometimes it is necessary for us to share your data for these specialist services to operate. Your data is shared only when strictly necessary and according to UK privacy regulation and the safeguards and good practices detailed in this Privacy Commitment. 

Partners
We may provide pet insurance for a partner under their brand name in which case we will share your data with them to fulfil the contractual requirements. We may also ask for your consent for a partner to send you direct marketing in which case we will share the record of your consent.

Regulators, Law Enforcement and Legal representatives
We may have to share your data with regulators such as the Financial Ombudsman Service or the FCA when requested. We may also be obligated to respond to requests from law enforcement agencies or court orders and we may be required to share your information with our legal representatives in relation to prosecuting or defending legal claims. 

Animal Friends’ processes may include the making of automated decisions at any stage, for the entering into or the performance of the contract including, but not limited to, generating a quote and the assessment of certain types of claims made in relation to the insurance contract; it may also apply to the selection and processing of the purchase of pet products and services.

You have a right not to be subject to decisions made only by automated means in which case you can ‘object’ to automated processing using the contact details listed under ‘Your Rights’.

Your choices

You can choose not to provide us with personal data or seek to limit our use of it - however this is likely to prevent us being able to sell or fulfil products or services or provide you with a quote or insurance policy or allow us to administer your services or products properly without processing your personal data.

You can turn off cookies by blocking cookies by using the cookie controls available on our website or via your browser. 

You can ask us not to use your data for direct marketing - we will inform you (before collecting your data) if we intend to use your data for direct marketing.

Your rights

You can exercise your rights by sending us an email at data.protection@animalfriends.co.uk.

• You have the right to be informed about the collection and use of your personal data. This Privacy Notice provides you with the information required under this right.
• You have the right to access information we hold about you.
  
  
• You have the right to make us correct any inaccurate personal data about you.
  
  
• You can object to us using your data for profiling you or making automated decisions about you. We may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behaviour). 
  
  
• You have the right to have a copy of your data in a portable format. We will give you a copy of your data in CSV so that you can provide it to another insurer. If you ask us and it is technically possible, we will directly transfer the data to the other insurer for you.
  
  
• You have the right to restrict the processing of your personal data. Under this right, we would only be able to store your personal data until the restriction is lifted.
  
  
• You have the right to be ‘forgotten’ by us. You can do this by asking us to erase any personal data we hold about you. There may be instances where we are unable to comply fully with this right. In those cases, we will provide you with the data that we have had to retain, the legal reason(s) for retaining this data and the retention period that applies.
  
  
• You have the right to lodge a complaint regarding our use of your data. Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the UK Information Commissioner’s Office, either by calling their helpline on 0303 123 1113 or as directed on their website at www.ico.org.uk .