- Any Aviva website that links to this Policy (“Websites”);
- Any services provided to you to help you manage new and existing products online through the Website(s) (“Electronic Services’).
- Social media or Aviva content on other websites;
- Mobile device and TV applications (“Apps”);
It also relates to our use of any personal information we collect through other means, such as email, in person or other third party sources.
- For information concerning Aviva please visit aviva.com
- For a full list of Aviva trading companies please visit aviva.co.uk
‘Customer’ means a Person on whose behalf your firm acts and who your firm has introduced to us on an advised or non-advised basis.
‘Person’ means a natural or legal person.
Our Approach to Privacy
The privacy and security of your personal information is very important to us. We want to assure you that your information will be properly managed and protected whilst in our hands.
The information we collect and how we collect it
Information you provide to Aviva
We may receive personal information about you and your dealings with us when you interact with us online. These interactions may include:
- Using the Aviva-for-Advisers website;
- Registering for or using our Electronic Services;
- Using Aviva Apps;
- Entering Aviva-for-Advisers competitions;
- Recording CPD with our CPD certificate;
- Taking part in Aviva Community Fund;
- Creating an Aviva-for-Advisers account; or
- Telephoning, texting, writing by post or email, or communicating via online channels with Aviva.
The types of personal information we capture may include:
- Basic personal details such as your name, address, e-mail address, telephone number and postcode;
- Additional information about your firm such as firm name, firm size, firm role and FCA number; or
- Your marketing preferences.
Collecting Data from your Customers
You must, at all times, hold the Customer's informed consent regarding access to, use of and processing of personal data relating to that Customer in order that such personal data can be accessed, used or processed by you, the User, or by Aviva. Aviva reserves the right to verify that you have such consent at any time and, if we have reason to believe that you do not have such consent, we will not accept any personal data from you, or supply you with any personal data about the Customer.
You shall not act in any way in relation to the Customer's personal data which might reasonably damage the reputation or goodwill of Aviva or its relationship with Customers. You must also promptly provide to us all information in your possession concerning any unauthorised or accidental disclosure of, or access to, the personal data of Customers including as a result of any unauthorised access to the Electronic Services.
Information we collect through Cookies and similar technologies
We collect information through “Cookies” and other similar technologies (e.g. pixel tags or links), to remember you when you visit the Websites and Apps and so we can improve your online experience to suit your needs. These help us understand how you and others use our Websites and Apps, view our products and respond to our advertising, so we can tailor communications (e.g. email) and enhance our overall product and service offering.
When you receive communications from us via email, we may use technology e.g. pixel tags or links to determine your use of and interest in our communications.
When you visit one of our Websites or Apps, we may record your device information including hardware and software used, general location, when and how you interact with our Websites and Apps and your registration and log-in activity when you use our online platforms, such as Aviva-for-Advisers. This information is retained and used to note your interest in our Websites and Apps and improve customer user experience.
Information collected from your use of third party websites, apps or technology
Sometimes you may be able to sign-in to an Aviva app or service via a third party service, such as Twitter or LinkedIn. If you choose to sign-in via a third party app, you will be presented with a dialog box the first time you do this, which will ask your permission to allow Aviva to access your personal information (e.g. your full name, date of birth, email address and any other information you have made publicly accessible).
We may use and share information from or with online sources, such as websites, social media and information sharing platforms. This information may be used to help tailor and improve our services and communicate with you effectively, as we know many of our users use a range of media channels.
Where we use or share information from or with these sources, we will respect any permissions you have set about how you would like your information to be used.
We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms.
You can opt out of marketing communications at any time by contacting us and letting us know, or following the link included in email correspondence received from us.
Use of Third Party information
We may obtain information about you from our third party suppliers and other third party databases, such as commercial property websites and government websites. This information may be used for marketing insight, pricing research, product development, business strategy and to detect and prevent fraudulent activity.
How we use information to improve our products and user experience
We may also use your information for research or statistical purposes, including to analyse how people use our Websites, view our products, respond to our advertising and to improve our understanding of what our users need.
We may use your information for training purposes, to improve our services and their delivery, for example by recording telephone calls.
How we use and share your information within the Aviva Group
We may share and aggregate information about you from across the Aviva Group to help us identify products and services that may be of interest to you, to tailor and package our products and services; to conduct customer research and develop marketing campaigns.
We may, as a matter of law, and without requiring notice or consent, use your and your Customers’ information for crime and fraud prevention, systems administration within the Aviva Group and to monitor and/or enforce Aviva's compliance with any regulatory rules and codes.
How we share your information outside of the Aviva Group
If you request a quote, or purchase a product or service on behalf of your Customer, the information may be shared with and processed by our associated companies, as well as the policy holder for the purposes of administration, and third parties providing services to them.
Your and your Customers’ information may be disclosed when we believe in good faith that the disclosure is:
- required by law;
- to protect the safety of our employees, the public or Aviva property;
- required to comply with a judicial proceeding, court order or legal process; or
- in the event of a merger, asset sale, or other related transaction; or
- for the prevention or detection of crime (including fraud).
We may share your information with regulatory bodies in the UK or if applicable, overseas, as well as with other insurance companies (directly or via shared databases) to prevent and detect fraud. Please see our section Fraud Prevention and Detection for more information.
Fraud Prevention and Detection
In order to prevent and detect fraud we may at any time:
- share information about you with other organisations and public bodies including the Police;
- undertake credit searches and additional fraud searches;
- check and/or file your details with fraud prevention agencies and databases, and if you give us false or inaccurate information and we suspect fraud, we will record this to prevent fraud and money laundering.
We can supply on request further details of the agencies and databases we access or contribute to and how this information may be used.
If you require further details contact us at:
Policy Investigation Unit,
Cruan Business Centre,
Westerhill Business Park,
123 Westerhill Road,
0345 300 0597
We and other organisations may also search these agencies and databases to:
- help make decisions about the provision and administration of insurance, credit and related services for you and members of your household;
- trace debtors or beneficiaries, recover debt, prevent fraud and to manage your accounts or insurance policies;
- check your identity to prevent money laundering, unless you furnish us with other satisfactory proof of identity;
- check details of job applicants and employees.
We may disclose your information to third party suppliers or service providers to conduct our business, for example, to help administer your Customers’ policies, to help us manage and store data, provide data analytics, conduct market research and to communicate with you effectively. This may include any online or digital partners we work with, so we, or our online or digital partners on our behalf, can communicate with you through their platforms.
In addition, unless you opt out of receiving communications, we may share your information with third parties who help run our marketing campaigns.
Data transfer and consent
Your and your Customer’s information may be transferred by any Aviva Group company to any country, including countries outside of the European Economic Area (EEA), for processing, storage, administration or any other use stated in this policy. The purposes and processing associated with any such transfer will comply with all applicable data protection regulations, including the UK Data Protection Act, and with our obligation to adequately protect and secure Your and your Customer’s personal information. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in the EEA.
By providing Your and your Customer’s personal information to Aviva you consent to the transfer of your information as described above.
We are committed to protecting the confidentiality and security of the information that you provide to us and we put in place appropriate technical, physical and organisational security measures to protect against any unauthorised access or damage to, or disclosure or loss of, Your information.
Managing your marketing preferences
We may provide you with updates and offers for Aviva’s products and services via direct communications (e.g. email). We will always give you the opportunity to ‘opt out’ of communications when you receive an email from us.
How to contact us
You or your Customer has the right to request a copy of all the personal information we hold about you or them (respectively) in a Subject Access Request. To do this you or they need to write to us at:
The Data Protection Team
A cheque for £10 should be enclosed payable to Aviva to cover our administrative costs in dealing with the request. We will take all reasonable steps to confirm the Customer’s identity before providing them with details of any personal information we hold about them.