Privacy Notice

The personal data we collect and process includes:

• Identity: title, name, date of birth, your pet’s name
• Contact: email address, postal address and telephone numbers (current and previous)
• Financial: bank details
• Transaction: details about payments to and from you and other details of policies (including any claims), products and services you have with us.
• Profile: usernames or passwords for any online accounts you have set up with us
• Usage: Information about how you use our website, policies, products and services
• Technical: Data from you visiting our websites such as:
  • IP addresses
  • Browser type and version
  • Domain
  • Device type

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Quote and Underwriting Data

The information used to calculate quotations, premiums and underwriting decisions, including the first part of your postcode, your pet’s breed and your pet’s age.

Special Category Data

We do not actively collect special category data. We will only hold special category data if this is information you have volunteered to us and provided consent for which will help us service your insurance contract with us more efficiently. 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with an insurance quote and/or policy). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• enter a survey;
• engage with our social media posts;
• request marketing to be sent to you; 
• use our co-browsing technology; 
• contact us for support via WhatsApp or LiveChat; or
• give us feedback or contact us.

Cookies, Storage and Access Technologies

We use cookies and other storage and access technologies (“SATs”) on our websites, mobile applications and digital services.

SATs are technologies that store information on, or access information from, your device. These technologies help us operate our services, improve performance, understand user interactions, support security measures and, where permitted, deliver personalised content or advertising.

The technologies we use may include:

• cookies;
• local browser storage;
• software development kits (SDKs);
• pixels and tags;
• device identifiers;
• scripts; and
• similar tracking technologies. 

Certain technologies are strictly necessary for our services to function and do not require your consent.

For non-essential technologies — including analytics, personalisation and advertising technologies — we will request your consent before using them where required under applicable privacy laws, including the Privacy and Electronic Communications Regulations (PECR).

You can withdraw or change your preferences at any time through our cookie settings tool.

With your consent, we and our advertising partners may use cookies and similar technologies to:

• understand your interests;
• measure advertising effectiveness;
• personalise content and advertising; and
• recognise your device across websites or services. 

These technologies may collect information about your browsing behaviour, device characteristics and interactions with our services.

Please see our Cookie Policy which can be located on any of our websites, for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data:

(a) Analytics providers such as Google Analytics; and

(b) HotJar tracking software.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used any of our services and you have not opted out of receiving that marketing.

We may also utilise your identity, contact, technical, usage, and profile data to reach out and offer support in converting your quotation into a policy. 

Third-Party Marketing

We do not sell, rent, or trade your personal data with third parties for their own marketing purposes.

Your personal data may only be shared with trusted service providers acting on our behalf and under strict contractual obligations. These service providers are only permitted to process your personal data in accordance with our instructions and are not allowed to use it for their own marketing activities.

We will only share your personal data with third parties for their own marketing purposes where you have provided your explicit consent, and where such sharing is permitted under UK data protection and privacy laws, including the UK GDPR and the Privacy and Electronic Communications Regulations (PECR).

Opting out

You have the right to request that we, or any third party, stop sending you marketing messages at any time.

You can do this by:

• Clicking the unsubscribe link in any marketing communication we or a third party send to you;
• Updating your marketing preferences by checking or unchecking the relevant boxes; or
• Contacting us directly at info@cruftspetinsurance.co.uk or 03330 30 83 72.

Please note that opting out of marketing communications will not affect our ability to process personal data that is necessary for the performance of a contract with you, such as data provided or generated as part of a product or service purchase, your use of a product or service, or other related transactions.

We may sometimes use an automated decision-making tool to assess claims where they have met a specific criterion. We utilise the information resulting from this to complete the assessment and make payment. You can ask for human intervention at any time by contacting info@cruftspetinsurance.co.uk. 

We use automated decision-making during the quote process to calculate your premium and make pricing and underwriting decisions. This includes using the first part of your postcode, your pet’s breed and your pet’s age, which are processed through our quote system. These factors help us assess insurance risk and decide whether cover can be offered and on what terms.

We use limited socio-demographic analysis and a segmentation tool to help us understand customer trends and ensure our marketing communications are relevant, appropriate, and proportionate. This tool allows us to group individuals based on limited information, such as interactions with our products or services, stated preferences, or general engagement data. Segmentation helps us avoid sending irrelevant communications and tailor our marketing to areas that may be of genuine interest. Segmentation is based on basic criteria and does not involve automated decision making that produces legal or similarly significant effects.

We may sometimes use your data for profiling for purposes other than marketing or making automated decisions about you. This is limited to the essential services we provide in order for us to manage our relationship with you. We may use speech analytics on recorded telephone calls to help us identify vulnerable customers and complaints, deliver training and ensure quality control. This data is reviewed manually. You have the right to object to us using your data in this way. Please see the ‘What are your rights’ section, and the ‘How to contact us’ section for details about how to do this.

General Third Parties:

• Our approved suppliers and contractors in order to be able to service our insurance policies effectively.
• Our insurers, legal advisors or other third parties who need access to it in the context of managing, investigation or defending claims or complaints.
• Your vet and/or therapist, to allow them to up-date your records that your pet is insured with us and/or, if they are going to treat your pet, to contacts us about your policy.
• Other insurers, to investigate, pursue, or recover losses relating to your claim. This may include situations where a third party (including third party’s animal) caused the incident. 

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Specific Third Parties:

• Ecclesiastical Insurance Office plc in relation to any third party liability insurance cover you have within your insurance policy for your dog.
• Catalyst Marketing Consultants for the purpose of customer market research.
• Meta Platforms Inc, Google and LinkedIn for the purpose of providing advertisements relating to Agria products and services.

Other:

• Regulatory or government bodies including police forces, local authorities or council, fraud prevention agencies, The Financial Conduct Authority, The Prudential Regulation Authority, the Swedish Financial Supervisory Authority (Finansinspektionen), The Financial Ombudsman Service, and His Majesty’s Revenue & Customs (HMRC) when it is necessary to do so to ensure compliance with relevant legislation.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 

All individuals have rights under data protection legislation which are listed below. Agria have measures and processes in place in order to deal with any requests made when exercising these rights.

Right to be informed

You have the right to be informed about the collection and use of your personal data. This information must be concise, transparent, intelligible, easily accessible, and it must be in clear and plain language. We provide this to you in the form of this privacy notice.

Right of access

You can request all personal data we hold on you. You have the right to contact us to request this using one of the contact methods stated below. We will review this and provide you with the information we have at the earliest opportunity, however, if the request is complex, we will contact you within 30 days to explain this and we may charge a fee for this if the request is excessive and/or manifestly unfounded. This right is also known as a ‘subject access request’.

Right to rectification

You have the right to rectification if your personal data is inaccurate or incomplete. We strive to ensure that we have the most accurate and up to date data, however, please advise us as soon as possible, if any of the information we hold on you is inaccurate and we will rectify it.

Right to erasure

You can request that your personal data is removed or deleted where there is no legal basis or compelling reason for this to be processed any longer. This right is more commonly known as the ‘right to be forgotten’.

Right to restrict processing

You have the right to request that the processing of your data is restricted in circumstances such as when you contest the accuracy of the data or when the processing is unlawful.

Right to data portability

Data portability allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. 

Right to object

You have the right to object to the processing of your personal data if you do not wish for it to be used for direct marketing purposes, and we must act on this. You can also object to any use of information where we have given ‘legitimate interest’ as our reason for using it. You must provide us with the reason for the objection and how it affects you as an individual. 

Where you have provided consent for us to process the data that we hold on you, you have the right to withdraw your consent that you provided to us at any time. If you have provided us with your explicit consent to process your data, you can withdraw this at any time. 

Right not to be subject to a decision based solely on automated processing

You have the right to ask for human intervention where a decision has solely been or is due to be made by automated means.

Right to Complain

We take all concerns seriously, and any information shared with us is treated with the utmost care.

Customer feedback helps us to deliver good outcomes and provides us valuable insights which are used to improve quality of service.

Making us aware of your concerns
You can raise concerns to our Complaints Department in several ways:

• Online form: https://cruftspetinsurance.co.uk/how-to-complain/
• By email: info@cruftspetinsurance.co.uk
• By telephone: 03330 3083 72
• By post: Complaint Department, Crufts Pet Insurance, PO Box 506, Manchester, M28 8EN

If you choose to contact us, please assist us by providing full details of your concern, together with any supporting documentation and contact details (including daytime telephone number). This information will help us to deal with your query promptly.

What you can expect

Following receipt of your complaint, we will acknowledge within five working days and we will keep you informed throughout our investigation. Our aim is to resolve all complaints in a timely manner and we will issue you a final response detailing the outcome. In the event we are not able to resolve within a timely manner, a holding letter will be issued to you.

Your rights

If you have previously submitted a data protection complaint and are not satisfied with the response you received from us, you have the right to contact the Information Commissioner’s Office (ICO), the UK’s data protection regulator. Their contact details are as follows:

• By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
• By telephone: 03031 231 113
• Online form: If you wish to raise a complaint to the ICO, you can do so via their website under 'Make a complaint' at the following link: https://ico.org.uk/make-a-complaint/

We will also provide details of the ICO within our complaint response letter.

We will keep your personal data and telephone conversations for a minimum of 3 years and up to 11 years after you cancel your policy or after the last claim is closed, whichever is the latter. We are required to retain your data for the amount of time as required by law or in order to defend potential legal claims. For all personal data that we retain, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We have a Data Protection Manager who has a high level responsibility for monitoring compliance with all relevant data protection regulations and is the lead contact for liaison with The Information Commissioners Office (ICO).

To exercise any of your rights mentioned above or with any specific queries on the personal data we hold on you, please contact us by post or email using the below details:

The Data Protection Manager
Agria Pet Insurance Ltd t/a Crufts Pet Insurance
1st Floor
Blue Leanie
Walton Street
Aylesbury~Buckinghamshire
HP21 7QW

Email: dataprotection@agriapet.co.uk