Partnership Competitions Privacy Policy

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).

This is the ‘parent’ company of the Royal London Group and is your main point of contact for all of our companies.

We may collect and process the following:

• Information about you – for example name, age, gender, date of birth.
• Contact information - for example email, address, postcode and phone number. 
• Online information – for example cookies and IP address (your computer’s internet address), if you use our websites.

Your information will be used in a number of ways including;

Competitions and giveaways

We will use personal information including name, email address and contact number submitted by entrants when entering the draw for the purposes of administering the draw.  We may also disclose the winner’s name and county of residence on our website.

Marketing

Sending you marketing information where you have provided permission to be contacted by post, email, text and other electronic means – you can easily change your mind and 'opt out' of receiving marketing information by emailing us: GDPR@Royallondon.com or ringing us on 0204 525 3777.

If, through any of our channels or platforms, you have opted in to receive any communications from our partners or any other organisations, e.g. the Lions, please contact them directly on their individual channels or platforms to unsubscribe from their databases.

Most of the information we receive comes directly from you when you sign up for one of our competitions. We may also get personal information about you from other sources:

• ‘Third party’ cookies – collect information on how visitors use our website. Our cookie policy can give you more information.
• Partners and sponsors – where you may have entered a competition and chosen to receive information from us.

Data Protection gives organisations a number of different conditions to allow us to process your information lawfully.

We’ll only use your personal information when one of these conditions has been satisfied. Below you can see how we use your information and the legal grounds for processing this:

Necessary for legitimate interests

We also use your information when we have a “legitimate interest” and that interest isn’t outweighed by your privacy rights. Each activity is assessed and your rights and freedoms are taken into account to ensure that we’re not being intrusive or doing anything beyond your reasonable expectation. We’ll assess the information we need, so we only use the minimum.

If you want further information about processing under legitimate interests you can contact us using the details below.

You also have the right to object to any processing done under legitimate interests. We’ll re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason we may still continue to use your information.

We use legitimate interests for the following:

As you’d expect, our employees will access your records in order to use your information for the uses mentioned above. However, only those employees who need access to particular information are given it. e.g. for sending out the cricket newsletter

• Our service providers and agents  e.g. Entrants’ personal data shall only be disclosed to those third parties who require it for the purposes of administering the prize draws and the interval participant prize, contacting the winners to notify them of their prizes and organising delivery of the prizes
• Regulatory Authorities - We may disclose personal information or other data relating to entrants of our competitions where permitted or required by law or statute, court or equivalent authority

We sometimes use third parties located in other countries to provide support services. As a result, your personal data may be processed in countries outside the European Economic Area (EEA).

These services will be carried out by experienced and reputable organisations on terms which safeguard the security of your information and comply with the European data protection requirements. Some countries have been assessed by the European Commission (EC) as being ‘adequate’, including the UK, which means their legal system offers a level of protection for personal data which is equal to the EC’s protection. Where the country hasn’t been assessed as adequate, the method we have chosen to safeguard your information is ‘standard contractual clauses’ within the legal agreement to safeguard the processing of your personal data.

The European Commission and the UK have recognised ‘standard contractual clauses’ as offering adequate safeguards to protect your rights and we’ll use these where required ensuring adequate protection for your personal data as prescribed by the GDPR.

We will always ensure your personal data is provided with adequate protection and all transfers of personal information outside the EEA are done lawfully.

We use Transport Layer Security (TLS) to encrypt and protect email traffic. However if your email service doesn’t support TLS, any emails we send or receive won’t be protected. We recommend you don’t send anything confidential to us by email.

Once we receive your information, we use strict procedures and security features to protect your information from unauthorised access.

We’ll keep your personal 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.  E.g. we will keep completion prize winners details for 6 months after the draw.

Your rights are outlined below. The easiest way to exercise any of your rights would be to contact our Data Protection Officer at the contact details provided. We will provide a response within 30 days, if not sooner. There is normally no charge for exercising any of your rights. We may ask you for proof of identity when you request to exercise some of these rights to ensure we are dealing with the right individual.

Access to your personal information

You have the right to find out what personal data we hold about you, in many circumstances. Please see the 'Contact us' section below for our contact details.

Correcting or adding to your personal information

If any of your details are incorrect, inaccurate or incomplete you can ask us to correct them or to add information.

Withdrawing your consent

If you have provided consent for us to use your personal data, you have the right to withdraw your consent at any time. If you withdraw consent, then we may not be allowed to use your data going forward. However, it would not invalidate any processing that was carried out before you withdrew consent.

Withdrawal of consent may impact the product and services we can provide to you, or the ability to administer your policy such as a claim. In this event, we will let you know what the impact would be.

Transferring your personal data to another organisation (data portability)

In some circumstances you can ask us to send an electronic copy of the personal data you have provided to us, either to you or to another organisation.

Objecting to the use of your personal data for legitimate interests

You also have the right to object to any processing done under legitimate interests. We will re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason, we may continue to use your personal data, if that reason is not outweighed by your privacy rights. However, we will inform you of that decision and reasoning for continuation of processing.

Objecting to direct marketing

You have a specific right to object to our use of your personal data for direct marketing purposes, which we will always act upon.

Objecting to automated decision making

You have a right to object if we have made an automated decision, including profiling, which has legal and significant effect against you. You may also have the right to challenge the decision and ask for a human review. These rights do not apply if we are authorised by the law to make such decisions and appropriate safeguards are in place to protect your rights.

Restricting the use of your personal data

If you are uncertain about the accuracy or our use of your personal data, you can ask us to stop using your personal data until your query is resolved. We will let you know the outcome before we take any further action in relation to this data. 

Right to Erasure

You can ask us to delete your personal data in some circumstances, such as if your policy has ended and we do not need to keep it for legal or regulatory reasons. If we are using consent to process your personal data and you withdraw it, you can ask us to erase it.

If you’re dissatisfied with how we’re using your personal data, you have the right to complain to the Information Commissioner. We’d encourage you to contact us first, so we can deal with your concerns.

The Information Commissioner`s office can be contacted by:

• Visiting their website, www.ico.org.uk
• Phone on 0303 123 1113
• Write to Information Commissioner`s Office Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you have any questions or comments regarding this privacy notice, or if you are unhappy about the way Royal London uses your information, please contact us using the details below.

• Post: Data Protection Officer, Royal London, Royal London House, Alderley Park, Congleton Road, Nether Alderley, Macclesfield, SK10 4EL
• Email: GDPR@Royallondon.com