Privacy Policy

Last updated: November 2018

Protecting your personal information is extremely important to us. It's especially important for a company like ours, as our customers trust us to look after a huge amount of sensitive information on everything from their date of birth to their medical history.

The way we collect, use, store and share your information is important. Our customers expect us to manage their information privately and securely. If we don't, they'll lose their trust in us.

This policy tells you how we collect and process your personal information. Please take a few minutes to read it, and show it to anyone else whose information you are sharing with us.

Who are we?

Investment Discounts On Line Limited is part of the Legal & General Group and is the registered data controller of your personal data for the purposes of the Data Protection Act. Trading names of Investment Discounts On Line Limited also known as theidol.com include comparecover.com, protectmypeople.com and clevermover.com.

What does this policy cover?

This privacy policy relates to customers who request a quote or apply for one of our provider products.

What is personal information?

When we talk about personal information we mean information about an individual that can identify them, like their name, address, email address, telephone number and financial details. It can relate to customers (including prospective cutomers), employees, shareholders, business contacts and suppliers. Any reference to 'information' or 'data' in this policy is a reference to personal information about a living individual.

What information do we hold?

We may collect and process the following personal information about you:

Type of data
Description
Examples of how we use it

Contact

  • Who you are
  • Where you live
  • How to contact you
  • Servicing your product
  • Marketing
  • Analysis & profiling
  • Enhancing our product and service offering

Personal Details

  • Age
  • Gender
  • Family details
  • Visual images & personal appearance
  • Financial Details
  • Lifestyle, health, medical information and social circumstances
  • Marketing
  • Analysis & profiling
  • Quotations provided
  • Product underwriting
  • Services selected

Transactional

  • Bank and/or card details
  • How you use your product
  • Servicing your product
  • Making sure our products and services are fit for purpose

Consent & preferences

  • Ways you want us to market to you
  • Marketing

Technical

  • Details on the devices and technology you use
  • Making sure our products and services are fit for purpose

Open data & public records

  • Information about you that is openly available on the internet
  • Product administration

Documentary data & national identifiers

Details about you that are stored in documents like:

  • Your passport
  • Drivers licence
  • Birth certificate
  • National insurance number

  • Prevent financial crime
Where do we get our information from?
  • Information you give us directly (such as when you request a quote or apply for one of our provider products, information regarding our products and services, or contact us by phone, e-mail etc.)
  • Information we collect about you or receive from other sources. This could be information you provide to us electronically (through our website or an online portal, for example), information we get from your online browsing activity, or information from a third party or from publicly available sources such as Regulatory Bodies e.g. FCA and Companies House. We may also receive information if you have been dealing with a financial adviser or have been introduced to us by another company (e.g. aggregator) or your employer (or their financial adviser). For more information on how we use cookies, please refer to our cookie policy.
How do we use your information?

We use personal information that we hold about you:

  • To share with the companies who provide the quotations for products and services that you request and to provide you with the information, products and services requested.
  • To provide you with marketing information about other services or products we offer across the Investment Discount On Line Limited brands that are similar to those that you've already enquired about, or services or products you've consented to receiving. If you have opted in to receive marketing from us, based on your marketing preferences, we may deliver this information by email, post, telephone or personalised online marketing via our own systems, social media platforms and/or other third party websites e.g. YouTube. Please note that if you choose not to receive online marketing, you will not see personalised messages using your personal data, however you may still see generic online advertising about our products and services. We will not sell your data to third parties for them to market to you. We may also send marketing to you using our 'legitimate interests', please see below for further information.
  • To tell you about changes to our services and products.
  • To comply with any applicable legal or regulatory requirements (including 'know your customer' checks, or to comply with any applicable regulatory reporting or disclosure requirements).
  • For carrying out market research, statistical analysis and customer profiling to help us to improve our processes, products and services (e.g. to understand digital behaviours and to develop more engaging communications).
  • To validate sales information.
  • To run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit.
  • For any other purpose that we've agreed with you from time to time.

When you request a quotation for a product or to receive a service from us, the online form (or in some instances the application form) you fill out or the resulting contract may contain additional conditions relating to the way we use and process your personal information. These will apply in addition to the uses described in this document.

Whilst Investment Discounts On Line Limited remain the data controller in relation to the information you provide to us, the product and service providers (such as those insurance companies we request quotes from) will also act as data controllers in relation to the information we pass to them. Requesting a quotation will be taken as acceptance for your data to be passed to our panel of insurance providers.

Each product and service provider has their own privacy policy and terms and conditions available on their website which will apply to their treatment of the data.

In some cases, we may use software or systems to make automated decisions (including profiling) based on the personal information we have or collect from others. These may include:

  • The detection of fraud and financial crime: To perform transaction monitoring, identity verification, money laundering and sanctions checks, and to identify politically exposed individuals. We are required by law to perform these activities which may be achieved using solely automated means to make decisions about you. We may use these activities to decline the services you have requested or to stop providing existing services to you.
  • Providing quotes and underwriting ratings: We may assess a number of factors including information about you and your health, lifestyle information such as your postcode, occupation and hazardous pursuits that you perform. These factors will be assessed against our panel of providers pricing and underwriting criteria which may include statistics regarding life expectancy, illness, injury and demographic risks. For general insurance the factors may include your claims history and where you live. Our panel of providers may use these activities to determine the price of your product and whether they should undertake the risk of insuring you - including how much insurance should be granted to you, how much you should pay for it and whether or not to insure you in the first place.
  • Servicing activities such as (i) Personalising the content and design of communications and online services and (ii) Determining when to provide tailored communications about your product and the appropriate channel(s) to use. These may be achieved using profiling in order to predict certain characteristics about you (e.g. your economic situation, interests, personal preferences or transactional behaviour). The activities will not have a detrimental effect on you.
Using your information in accordance with data protection laws

Data protection laws require us to meet certain conditions before we're allowed to use your personal information in the way we describe in this privacy policy. We take these responsibilities extremely seriously. To use your personal information, we'll rely on the following conditions, depending on the activities we're carrying out:

  • Providing our services to you: We'll process your personal information to carry out our responsibilities resulting from any agreements you've entered into with us and to provide you with the information, products and services you've asked from us which may include online services.
  • Complying with applicable laws: We may process your personal information to comply with any legal obligation we're subject to.
  • Legitimate interests: To use your personal data for any other purpose described in this privacy policy, we'll rely on a condition known as "legitimate interests". It's in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively. We may use your information to:

    • Carry out market research and product development, which can include creating customer demographics and/or profiling.
    • Develop and test the effectiveness of marketing activities.
    • Develop, test and manage our brands, products and services.
    • Study and also manage how our customers use products and services from us and our business partners.
    • Manage risk for us and our customers.

    This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.

    The outcome of this balancing test will determine whether we can use your personal data in the ways described in this privacy policy (except in relation to marketing, where we'll always rely on your consent). We'll always act reasonably and give full and proper consideration to your interests in carrying out this assessment.

  • Consent: We may provide you with marketing information about our services or products where you've provided your consent for us to do so.

    You may opt out of marketing at any time by visiting our Unsubscribe service, emailing customerservices@theidol.com or by telephoning our customer service team on 0800 915 7885.

  • Special category (sensitive) data: Where you have consented, we will process any medical & health, racial & ethnic origin, genetic & biometric or sex life & sexual orientation information you have provided, and any other sensitive information obtained from a third party, solely for the purposes of allowing us to administer your product.
  • Criminal Conviction Data: Where you have consented, we will process this type of information solely for the purposes of allowing providers to underwrite and administer your product.

Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.

How long do we keep your information for?

We'll keep your personal information in accordance with our internal retention policies. We'll determine the length of time we keep it for based on the minimum retention periods required by law or regulation. We'll only keep your personal information after this period if there's a legitimate and provable business reason to do so.

Who do we share your personal information with?

We'll only disclose your information to:

  • Our product providers, insurance service providers, third-party suppliers, contractors and the company that has referred you to us (including their third-party suppliers) or the purposes listed under 'How do we use your information?' above.
  • Selected third parties, so that they can contact you with details of the products and services that they provide, where you have expressly opted-in or consented to the disclosure of your personal data for these purposes.
  • Our regulators, law enforcement or fraud prevention agencies, as well as our business partners etc.

Additionally, we may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we'll disclose your personal data to the prospective seller or buyer of such business or assets.
  • If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
  • If you have been dealing with a financial adviser, we'll provide information about your product or service and, where appropriate, with other information about your dealings with us, to enable the adviser to give you informed advice.
  • For employer sponsored schemes, we may share some details of your plan with your employer and any professional advisor(s) they appoint on their or your behalf to service and provide accurate financial advice about the scheme.
  • In order to apply the terms of any service with you.
  • If we're under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
  • To protect you and your selected provider from financial crime, we may be required to verify the identity of new and sometimes existing customers. This may be achieved by using reference agencies to search sources of information relating to you (an identity search). This will not affect your credit rating. If this fails, we may need to approach you to obtain documentary evidence of identity.
  • If you make a claim, we'll share your information (where necessary) if requested by your selected insurance company to prevent fraudulent claims.

Additionally, your information, including special category and criminal conviction data, may be disclosed to any other insurance company to whom you apply for products or services.

If you've been introduced to us by another company (such as aggregator and price comparison website, your employer or their financial adviser) we may share your information with them, as well as your selected insurance provider, to enable them to:

  • Administer and service your product.
  • Carry out market research, statistical analysis and customer profiling.
  • Where you have consented, send you marketing information by post, telephone, email and online about their products and those of carefully selected third parties.
  • Assist you with your application process. (aggregator and price comparison websites only).

Fraud prevention

Investment Discounts On Line Limited may also share information about you with other organisations and public bodies, including the police and we may check and/or file your details with fraud prevention agencies and databases. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information.

Investment Discounts On Line Limited and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

  • Checking details on proposals and claims for all types of insurance.
  • Checking details of job applicants and employees.

Investment Discounts On Line Limited and other organisations may access and use from other countries the information recorded by fraud prevention agencies. Please contact us if you wish to receive the relevant details of the fraud prevention agencies by emailing customerservices@theidol.com.

Investment Discounts On Line Limited or your selected provider may also check the details of other parties related to your contract, including verification of identity. This includes beneficiaries, trustees, settlors, third party premium payers, executors or administrators of your estate, parties with power of attorney and any other beneficial owner.

Transferring your data outside the EU

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") to third-party suppliers, delegates or agents. We'll take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this privacy policy.

We'll only transfer your data to a recipient outside the EEA where we're permitted to do so by law (for instance, (A) where the transfer is based on standard data protection clauses adopted or approved by the European Commission, (B) where the transfer is to a territory that is deemed adequate by the European Commission, or (C) where the recipient is subject to an approved certification mechanism and the personal information is subject to appropriate safeguards, etc.).

Unfortunately, sending information via email is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.

Your Rights

You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner's website. If you wish to exercise any these rights, please get in touch with our customer services team by emailing customerservices@theidol.com or by telephoning our customer service team on 0800 915 7885.

Your Rights

1.   The right to access the personal data that we hold about you.

2.   The right to make us correct any inaccurate personal data we hold about you.

3.   The right to make us erase any personal data we hold about you. This right will only apply where for example:

  • We no longer need to use the personal data to achieve the purpose we collected it for
  • You withdraw your consent if we're using your personal data based on that consent
  • Where you object to the way we use your data, and there is no overriding legitimate interest

4.   The right to restrict our processing of the personal data we hold about you. This right will only apply where for example:

  • You dispute the accuracy of the personal data we hold.
  • You would like your data erased, but we require to hold it in order to stop its processing.
  • You have the right to require us to erase the personal data but would prefer that our processing is restricted instead.
  • Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.

5.   The right to object to our processing of personal data we hold about you (including for the purposes of sending marketing materials to you).

6.   The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.

7.   The right to withdraw your consent, where we're relying on it to use your personal data (for example, to provide you with marketing about our services or products).

8.   For automated decisions (including profiling), you have the right to:

  • Obtain an explanation of the decision and challenge it
  • Request for the decision to be reviewed by a human being
Contacts and complaints

If you have any questions about this privacy policy or wish to exercise any of your rights, including changing your marketing preferences, please get in touch with our Customer Services team.

If you have any concerns about the way we process your personal data, or are not happy with the way we've handled a request by you in relation to your rights, you have the right to make a complaint to the Information Commissioner's Office. Their address is:

First Contact Team
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

Data Protection Officer

If you'd like to exercise your right to access any personal information that we hold about you, write to: theidol.com, The Edge, Eden Business Park, Penrith, Cumbria CA11 9FB

You can also contact our Data Protection Manager directly with any questions or issues relating to the way we process your personal information:

Name: Mary Davis
Email address: datacontroller@theidol.com
Address: The Edge, Eden Business Park, Penrith, Cumbria, CA11 9FB


If you are not satisifed with the way we deal with your enquiry you can escalate your request to:

Group Protection Officer
Email address: data.protection@landg.com
Address: 1 Coleman Street, London, EC2R 5AA

Our Product & Service Providers

This list details the product & service providers to whom we disclose your information.

Travel
Direct Travel, AnnualTravelInsurance, Flexicover, Insurance Republic, Insure With Ease, Insurefor, multitrip.com, TopDog, Your Travel Cover, Big Blue, Insure And Go, Coverwise, Debenhams, Explorer, Asda, World First, ERV, TravelInsurance, CoverForYou, Good To Go, Ok To Travel, Admiral, Spectrum, TravelTime, Southdowns, AllSafe, Virgin Money, TripSure, TravelInsurance4Medical, MoreThan, Puffin, Cedar Tree, Now, RAC, JustTravel, Post Office, Outbacker, Legal and General, Insurefor Med, Fit2Travel, Thomas Cook, InsuraTrip, Fortify Insurance, Fortify Insurance Med, Zurich, Big Blue Med, Debenhams Med, Free Spirit, Holiday Extras, TheAA, AllClear, StartTravel, Saga Services Limited, Sainsburys Bank, EconomyCover, esure

Life
Legal & General, LV=, AEGON, Zurich, VitalityLife, AIG, Beagle Street

Pet
Pet Pals, Computerquote, Purely Pets, Pet Protect, Healthy Pets, AnimalFriends, Vetsmedicover, Pet-Insurance, John Lewis, Argos, Legal and General, Paws and Claws, UIS Pet, Marks and Spencer, Admiral, EandL, Post Office, Lifetime Pet Cover, 4Paws Pet Insurance, SunLife, PDSA, Puffin, Debenhams, The Insurance Emporium, Scratch and Patch, Geoffrey Pet, Everypaw

ProtectMyPeople
AmTrust, Aviva, Canada Life, Ellipse, Legal & General, Lutine, MetLife, Omnilife, Unum, Zurich

Over50s
Pet Pals, Computerquote, Purely Pets, Pet Protect, Healthy Pets, AnimalFriends, Vetsmedicover, Pet-Insurance, John Lewis, Argos, Legal and General, Paws and Claws, UIS Pet, Marks and Spencer, Admiral, EandL, Post Office, Lifetime Pet Cover, 4Paws Pet Insurance, SunLife, PDSA, Puffin, Debenhams, The Insurance Emporium, Geoffrey Pet, Scratch and Patch, Everypaw

AnnuityReady
Legal and General, Aviva, Hodge Lifetime, Just

Servicing
Loqate

BL BR

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