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Assurant® Website Privacy Notice

This Website https://protectyourbubble.my-hubb.co.uk/portalserver/log-in (the "Service") is operated by Lifestyle Services Group Limited, with mailing address of PO Box 98, Blyth, NE24 9DL, a member of the Assurant, Inc. group of companies (hereinafter, “We”, “Us”, “Our” or “Company”). Assurant General Insurance Limited is the data controller of your Personal Information in the context of the Service.

This Privacy Notice (“Notice”) describes how We will process and protect personal information relating to an identified or identifiable individual (“Personal Information”) when you use the Service, which allows users to create an account, update account details, access policy documents and forms (for example, view policy terms and conditions, print certificates of coverage, print claims forms), and contact customer support, and applies to your use of the Service. We also use the Personal Information to provide Our insurance or product services to you, to communicate with you, and to track usage of the Service and Our products and services. Your Personal Information shall be held and used in accordance with applicable legislation relating to the protection of Personal Information (the “Applicable Law”).

This Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other services, please refer to the policies provided in association with each.

1. Personal Information We Collect

We collect your Personal Information in the following situations:

1.1 When you Create an Account

We collect Personal Information from you when you create an account on the Service. To create an account on the Service, We ask users to provide Us with their full name, telephone number, mailing address, postcode, email address, date of birth, banking details (name, account number, bank name, sort code) and password. We will also collect your Internet Protocol (“IP”) address.

1.2 When you communicate with Us or contact Us for Customer Support

When you contact Our customer support team (for example, when you enquire about the status of your account), We will collect information that you provide to Us in your communications (such as the query or issue that you have raised).

1.3 When you access the Service

We collect information about devices used to access Our Service, (including IP address, browser used, browser language preferences, screen settings). Additionally, We use cookies and similar technologies such as web beacons to collect information about how you use and navigate Our Service (for example, the pages that you view and links that you click). We use cookies to help Us recognize you, improve your experience, increase security, and measure use and effectiveness of Our services. For more information about the cookies We utilize on the Service, please view Our Cookie Notice.

2. Purposes and Legal Basis for the Processing of your Personal Information

We process your Personal Information for the following purposes:

  • To fulfil a service contract, or take steps linked to a service contract: this is relevant where you have entered into a service contract with Us. This includes:

    • providing the Service;
    • verifying your identity;
    • taking payment from you;
    • making reimbursement payments to you; and
    • communicating with you.
  • As required by Us to conduct Our business and pursue Our legitimate interests, in particular:

    • We will use your Personal Information to provide the Service and other products and services that you have requested, and respond to any comments or complaints you may send Us;
    • We monitor use of the Service, and use your Personal Information to help Us to track and analyse preferences and trends, evaluate possible new features, functionality and services, and improve Our Service.
    • We use Personal Information to help Us recognize you on the Service, improve your experience, increase security of Our networks and systems, and measure use and effectiveness of Our Service.
    • We use Personal Information you provide to investigate complaints received from you or from others, about the Service or Our products and services. We also use this Personal Information to track potential issues (for example, issues with fulfilment of services) and trends to better serve you;
    • We use Personal Information to make decisions about, and to effect, reorganizations or sales of all or part of Our business;
    • We monitor customer accounts to prevent, investigate and/or report fraud, misrepresentation, or crime, in accordance with Applicable Law; and
    • We will use Personal Information in connection with legal claims, compliance, regulatory and investigative purposes (for example, theft and fraud investigations) as necessary (including disclosure of such information in connection with legal process or litigation).
  • Where you give Us consent:

    • We place cookies and use similar technologies in accordance with Our Cookie Notice and the information provided to you when those technologies are used; and
    • On other occasions where We ask you for consent, We will use the data for the purpose which We explain at that time.
  • For purposes which are required by law:

    • In response to requests by government or law enforcement authorities conducting an investigation; and
    • Responding to complaints where We are under a legal or regulatory obligation to adhere to a complaints handling procedure.
  • Withdrawing consent

    • Wherever We rely on your consent, you will always be able to withdraw that consent, although We may have other legal grounds for processing your data for other purposes, such as those set out above. Where you have given Us your consent, you can withdraw it by using the mechanism described to you at the time that your consent was obtained, or by contacting Us

3. Third Party Links

We link to other websites which are not within Our control. Once you have left Our website, We are not responsible for the protection and privacy of any information which you provide to such other websites. It is therefore recommended that you exercise caution and read such websites’ privacy policy.

4. Disclosure of Personal Information

4.1 Disclosure to Our Affiliates

We will disclose your Personal Information to other Assurant group companies for the purpose of performing tasks that directly relate to the provision of the Service. For example, We share your information with Our affiliates provide contact centre services and customer support.

4.2 Disclosure to Our Service Providers and Partners

We employ third party companies and individuals to facilitate the Service (for example, customer support, customer communications, audit, application or database hosting, development, logistics, payment processing, credit reporting bureaus, legal referral services, and for fraud detection and prevention purposes). These third parties have limited access to your Personal Information to perform these tasks on Our behalf and are obligated to Us. The personnel of such third parties who use your Personal Information is limited to those individuals which are authorized to do so on a need-to-know basis and as necessary to provide these business services to Us. We do not authorize such third parties to disclose or use this Personal Information for other purposes.

4.3 Disclosure to Public Authorities

We may disclose your Personal Information if required for the purposes above, if mandated by law or if required for the legal protection of Our legitimate interests in compliance with Applicable Law.

4.4 Other Categories of Recipients

We may also disclose your Personal Information, usage information, and other information about you to parties acquiring part or all of Our assets, as well as to attorneys and consultants. Also, if any bankruptcy or reorganization proceeding is brought by or against Us, your Personal Information may be considered a company asset that may be sold or transferred to third parties.

5. Where your Data is Processed

In providing the Service, Personal Information may be transferred to, and processed in, countries where data protection and privacy regulations do not offer the same level of protection as the European Economic Area (“EEA”) and other parts of the world. Sharing Personal Information with Our affiliates involves transfers outside the EEA to the US. For example, if we share your data with other Assurant group companies to provide the Service (for example – to create an account that you have requested), that data will be processed by Our affiliate located in the United States.

Where Personal Information is transferred outside the EEA to a country that is not subject to an adequacy decision by the EU Commission, it is adequately protected by European Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests to us.

6. Your Choices and Rights

In some countries, you have the right to request access to, correction of, and deletion of your Personal Information, and to restrict the processing of your Personal Information, under Applicable Law. You also have the right to request a structured commonly-used and machine-readable copy of Personal Information that you have provided to Us for a contract or with your consent, and to ask Us to transmit (port) this Personal Information to another controller.

You may also object to Our processing of Personal Information in certain circumstances (in particular, where We don't need to process the information to meet a contractual or other legal requirement, or where We are using the data for customer experience surveying purposes (see section 2).

You can exercise any of your rights by contacting Us. In order to safeguard your Personal Information from unauthorized access, We may ask that you provide sufficient information to identify yourself prior to providing access to your Personal Information.

In certain situations, and subject to Applicable Law, We may not be able or obliged to comply with part or all of your individual requests. For example, We may not comply with an access request if doing so would reveal Personal Information about another person, or comply with a deletion request relating to information which We are required by law to keep or have compelling legitimate interests in keeping. Please note that We have the right to refuse requests which are manifestly unfounded or excessive (for example, due to their repetitive character).

If you have unresolved concerns, you have the right to complain to an EU data protection authority ('supervisory authority') where you live, work or where you believe a breach may have occurred.

To provide certain parts of the Service (for example – update your contact details and access your benefits), the provision of Personal Information is mandatory: If relevant data is not provided, then We will not be able to provide certain parts of the Service. All other provision of your information is optional. If you do not wish to provide optional information, then your experience on Our website may be less personalised.

7. Communications from Us

We communicate with you through email and the Service. We will send you service-related communications (for example, “Welcome and Thank you Registering” and “It’s Time to Renew Your Service”).

You can change your email and contact preferences by contacting contact Us. Please be aware that you cannot opt-out of receiving service-related messages from Us.

8. Data Retention

We retain Personal Information you provide as needed to provide the Service. We may retain your Personal Information if retention is reasonably necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Notice and Our Terms of Use. We may retain Personal Information for a limited period of time if requested by law enforcement. Our customer support may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but We generally delete or de-personalise transaction-related data consistent with this Notice. Once Personal Information is anonymized, We may retain and use such information. Additionally, We maintain logs and backups for security, debugging, and site stability purposes for up to 30 days after your transaction has been completed.

We typically delete logs and other backup information through the deletion process within 30 days of your last activity, except as noted in Section 5. Where We process Personal Information in connection with performing a contract, We keep the data for 6 years from your last interaction with Us.

9. Information Security

We have implemented safeguards designed to protect your Personal Information in accordance with industry standards.

We have measures in place to restrict access to Personal Information to those individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the Personal Information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide Personal Information collected through the Service to keep such information secure and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.

10. Important Information

10.1 Minimum age

We do not knowingly collect Personal Information from anyone under the age of 18. You must be at least 18 years of age to use the Service.

10.2 Changes to this Notice

We may update this Notice from time to time. If We make any material changes to Our Notice, We will notify you by email or by means of a notice through the Service, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use the Service. Please review changes carefully.

10.3 Contact Us

For customer enquiries, please contact Us at: Lifestyle Services Group, PO Box 98, Blyth, NE24 9DL, or call Us.

We welcome your questions or comments regarding this Notice. Please write to Assurant General Insurance Limited (an Assurant group company), Data Protection Officer, PO Box 98, Blyth, NE24 9DL, or send Us an email at dataprotectionofficer@assurant.com. You may also write to Us at Assurant Privacy Office, Post Office Box 979047, Miami, FL 33197-9047, USA.

Effective date: [DATE]