Pensions and services app privacy notice
This notice describes how we collect, store, use and share personal information in relation to our Pensions and Services App (the “App”).
1. Who we are
When we say ‘we’ or ‘us’ in this notice we’re referring to Royal London Mutual Insurance Society Limited, a company registered in England and Wales (registration number: 99064).
2. What personal information will we hold about you?
We’ll collect information on how and when you use our App – this includes:
- the screens you access.
- the time and date you access the mobile app.
- the make and model of your mobile device.
- the operating system, like iOS and Android.
We collect all this information through Google Analytics and use it to enhance our App and improve your experience.
We don’t have access to your IP address. Google do, but they don’t keep it.
3. How we use your information
As a customer of Royal London we use your information in a number of ways.
We use your information to identify you and to give you access to your plan through our App.
You also have the option to sign up for push notifications through the App. You will not receive push notifications unless you sign up to receive them. If you do sign up to receive push notifications, you are consenting to Royal London using your personal information to provide these notifications to you. These notifications will be pushed by us from the App to your mobile device from time to time. The notifications may be used for a variety of reasons, including providing you with information about Royal London and its initiatives (for example, ProfitShare and membership information), providing information produced by Royal London on financial affairs or to provide information in relation to plan(s) you have with us. At any time, you can manage your push notification preferences or deactivate these notifications by turning off the notification settings in your mobile device settings. Turning off push notifications will not impact the use of the App.
For further information on how we use your personal information for your pension plan in general, please visit royallondon.com/privacy
4. What are our legal grounds for using your personal information?
We use the legal grounds of legitimate business interests for this activity to give you access to your plan through the App. The personal information used helps us to increase engagement with our customers and to provide them with relevant information in respect of their plan.
We keep hold of our customer’s usage information to help us to understand how the App is being used at any given time and to help us to decide on future enhancements that we might want to make to the App.
We use the legal ground of consent to send you push notifications, which can be withdrawn at any time via the settings on your mobile device.
5. Who sees and uses my personal information?
Certain employees of Royal London are given access to your personal information. We also share your information with other companies but we only use trusted third parties, such as:
- IT companies.
- Legal advisers and legal/regulatory bodies.
- Regulators such as the Information Commissioner’s Office (ICO).
We make sure the use of your information is protected and we’ll never sell your information.
6. Overseas transfers
Our App is hosted and supported by Royal London staff, so we don’t need to transfer your information outside of the EU (the UK and Ireland).
7. How long do we keep your personal information?
If you delete our App from your mobile device then you will still be able to access our online services with your account log-in details.
We will only keep App usage information for as long as it’s considered necessary, for the purpose for which it was collected, and to comply with our legal and regulatory requirements.
8. What are my rights?
- Access – You have the right to find out what personal information we hold about you.
- Rectification – If any of your details are incorrect or incomplete, you can ask us to correct them for you.
- Erasure – You can ask us to delete your personal information in some cases.
- Object – If you have concerns about how we’re using your information for analysis, you have the right to object.
- Restriction – You have the right to restrict the use of your information in some circumstances.
- Data portability – you can ask us to send an electronic copy of some of your information, either to you or to another organisation.
If you wish to exercise any of these rights please contact us using the details in Section 12.
9. Right to complain to the supervisory authority?
If you’re unhappy with how we‘re using your information, you have the right to complain to the Information Commissioner’s Office. We’d encourage you to contact us first, so we can help with your concerns.
The Information Commissioner’s Office can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
10. Changes to the way we use your information
If we want to use your personal information for a new purpose which we haven’t previously told you about, we’ll contact you to explain the new use of your information. We’ll set out why we’re using it and our legal reasons.
11. Changes to our privacy notice
Making sure that we keep you up to date with privacy information is a continuous responsibility and we keep this notice under review. We’ll update our notice as changes are required.
This privacy notice was last updated on 5 March 2020
12. Contact us
If you have any questions or comments regarding this privacy notice, or if you’re not happy with the way Royal London uses your information, please contact us using the details below. You can also call if you want this information in another format such as Braille, large print or audio.
How to contact our Data Protection Officer (DPO)
By email: GDPR@royallondon.com
By telephone: 0800 085 8352
By writing to us:
Data Protection Officer
Royal London House
Alderley Road Wilmslow
Cheshire SK9 1PF