We want you to be confident about how we use your personal information. As a regulated company and information controller we take our responsibilities for the security and management of your personal information seriously. That’s why we invest in our systems and processes to ensure that the way we collect, use, share, and store your information meets both the regulatory and our own high standards.
We may change the way we use personal information. When this happens we’ll inform you when we need to, for example, on our website.
Who we are and how to contact us
LV= is made up of a number of different companies within the LV= group which all have the same high standards regarding data protection.
✔ The data controller for our lifetime mortgage products is Liverpool Victoria Equity Release Limited.
✔ The data controller for UIA insurance policies is Liverpool Victoria Life Company Limited.
✔ The data controller for unemployment cover within the LV= Mortgage and Lifestyle Protection plan is LV Protection Limited.
✔ For all other life products, the data controller is Liverpool Victoria Friendly Society Limited.
If you have any questions about how we process your personal information please get in touch with us at: Life Customer Support, LV=, County Gates, Bournemouth, BH1 2NF or email us at: [email protected]
You can also contact our Data Protection Officer: Data Protection Officer, LV= County Gates, Bournemouth, BH1 2NF or via email at [email protected]
Information we collect
We only ask for information that we need and have strict controls to keep it safe. We collect personal information to provide our quotes, products and services. Without the information we ask for, we can’t provide you with the products or services you have requested and, where applicable, it may affect the outcome of any claims made. The personal information we collect will be held in digital and/or paper files. We collect personal information such as name, address and date of birth. For some products, we may also request information about health, lifestyle, leisure activities, family, occupation and finances.
We collect personal information when you:
✔ ask for a quote or apply for a policy
✔ buy and / or use a product or service
✔ ask us a question
✔ make, or inform us of a claim or incident
✔ make or receive a payment
✔ update your personal details
✔ change your cover
✔ register a complaint
✔ take part in market research (eg customer satisfaction surveys)
✔ update how we contact you with marketing
✔ change ownership of a policy (for example, putting a policy in trust)
✔ nominate a beneficiary for the policy
How we use and share your personal information
The personal information we ask for will be used by us and third parties who process information on our behalf. This includes organisations who administer or assist us in administering policies, servicing claims and reinsurers.
Legal ground for processing personal information
We collect personal information to provide our quotes, products and services.
As a regulated financial services organisation, we’re required to comply with legal and regulatory obligations such as the prevention, detection and reporting of fraud and other financial crime.
We’ll process personal information for our legitimate interests when we have a business reason to do so. For example, to:
✔ develop, improve, and personalise our products, pricing and services
✔ enhance our customer service, experience, and relationship (for example, customer and market research, business analysis, provide relevant product and service information)
✔ improve the relevance of our advertising and marketing campaigns
✔ help detect and prevent fraud and financial crime
✔ develop and improve our administration, security systems and insurance applications
✔ promote responsible lending and help prevent over-indebtedness
✔ share it with third parties in the event of an organisational change (for example, if we bought or merged with another organisation)
✔ share personal information with other LV= companies
If we need your consent to process personal information we’ll ask for this first. You can withdraw your consent at any time.
In an emergency, we’ll manage your products or claims until you or someone else is able to act on your behalf.
Payment card details
We use the payment card or bank details provided to enable money to be paid to us and for us to pay money out. We use a secure payment processor for all card payments. When a payment is processed we receive a unique transaction code and an extract of your card number, which we store as a record of the transaction.
If we intend to make a change to a payment, we’ll always get in touch in advance to tell you if and when we intend to change payments in any way.
Automated decision making and profiling
We use automated decision making to help determine the prices, policy terms, relevant products/services, when you research or ask for a quote, buy our services or products, make any changes, renew or make a claim. We may also profile you based on your personal information and that provided by third parties. Profiling may be used to help determine the likelihood of a claim or policy transaction being fraudulent.
Profiling will also be used to enhance our understanding of you and to help us make our business decisions (for example, product design, pricing, customer journeys or marketing strategy). If you’ve chosen to receive marketing information from us, profiling will be used to make our marketing more relevant, for example, personalise the channels used to market to you, the marketing messages used and the offers you’re sent.
Please see the ‘Your personal information rights’ section below.
In the event that we process personal information outside the UK, the processing in those locations is protected by UK and European data standards.
Where a claim occurs abroad we will also send data to the necessary service providers and agencies as required to service your claim.
Financial crime & fraud prevention agencies
The personal information we have collected will be shared with crime prevention agencies who will use it to prevent financial crime and fraud and to verify your identity. If financial crime or fraud is detected, you could be refused certain services, finance or employment. Where we suspect financial crime or fraud, we may cancel any policies you have with us, not be able to pay any claim or offer you the requested product or service. We may share relevant information with crime and fraud prevention agencies, law enforcement agencies and other relevant organisations.
We use your information to make sure we comply with any financial sanctions that apply in the UK and overseas. This includes;
✔ checking your information against sanctions lists
✔ sharing your information with HM Treasury and international regulators if required.
LV= will contact you if more information is needed to comply with any financial sanctions.
Your personal information will be used or disclosed as required by regulators to monitor and enforce our compliance with any regulation.
Credit search and identity check
In order to process the product or service you have applied for, we may supply your personal information to credit reference agencies (CRAs) and they’ll give us information about you, such as about your financial history. We do this to assess creditworthiness, check your identity, manage your account, trace and recover debts and prevent fraud and other financial crime.
We’ll also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your personal information with other organisations. Your data will also be linked to the data of any joint applicants or other financial associates you have.
Intermediaries or brokers
If we get your details from a financial intermediary or broker, personal information (for example, policy details, claims, payment, suspected fraud and other financial crime information) will be shared with them.
Partner or affinity associations
If you get a quote or buy through one of our partner or affinity associations, we may pass some of your personal information back to them (for example, policy details, claims, membership and suspected fraud and other financial crime information).
Price comparison or other introductory services
If you get a quote on a price comparison website or another introductory service, the information you give them is passed to us so you don’t need to re-enter your details. We’ll also pass your personal information (for example, policy details, and suspected fraud and other financial crime information) back to them.
We may use public information such as electoral roll, county court judgments and social media.
Specialist services we use
We use other companies to provide some services, for example, banks and building societies, legal service providers, communication services, debt recovery agencies, marketing, fraud and other financial crime investigation services, and companies to help us find customers we have lost contact with. We’ll give them the personal information they (or their sub-contractors) need to manage their service.
Market research agencies
We may share your personal information with market research agencies who will conduct market research and business analysis on our behalf.
Reinsurers and reinsurance brokers
We may need to share any personal information, including policy, claims, medical, and suspected fraud and other financial crime information, with our reinsurers and reinsurance brokers. Reinsurers provide insurance policies to insurance companies. Insurance companies engage a reinsurance broker to advise and assist in arranging a re-insurance policy.
Medical and other health services
For some products, if you apply, amend or make a claim on your policy we may need additional medical information.
If we need to get a medical report from your doctor, you will need to give consent. We will contact you if this happens to let you know what is needed.
We also use other companies to provide additional health and medical services, for example nurse screenings or rehabilitation support in the event of a disability claim. We’ll give them the personal information they need to manage their services (for example, contact information to make an appointment). Again, we will let you know if this happens.
Other insured parties
An insured party on your policy or product may notify us of an incident or claim against your policy.
Law enforcement and government agencies
Information may be given to us by law enforcement agencies (for example, the police) which may affect a policy or ongoing claim.
Giving someone permission to talk to us about your policy or product
We can only talk about your policy to you or someone we’re satisfied that you’ve authorised to talk to us, on your behalf.
When you contact us, personal information that you give us will be recorded. This helps us improve our customer service, train our staff, respond to complaints and prevent fraud and other financial crime.
All communications will be in English. You can get this document from us in writing, Braille, large print or an audible format by contacting us.
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How long we keep your personal information
We keep personal information to provide our quotes, products and services. We may also keep personal information after the product or service has ended to allow us to manage complaints or claims and to ensure we meet our statutory and regulatory obligations, for example, as laid down by Her Majesty’s Revenue and Customs (HMRC) or the Financial Conduct Authority. The length of time we keep personal information will vary depending on the type of product or service you hold with us.
Protection products - for example, Life Insurance (term and whole of life), Critical Illness Insurance, Income Protection.
If you complete an application or take out a policy with us we’ll keep personal information for up to 7 years after the policy ends.
If you get a quote or pre-underwriting enquiry from us but don’t go on to complete an application, or buy a policy from us, we’ll keep personal information for up to 6 months.
Pension products - for example, Flexible Personal Pension Plan, Flexible Transitions Account, Protected Retirement Plan, With Profits Retirement Plan, LV= 1996 Pension Scheme, Liberty Pension Plan.
If you take out a pension product with us or transfer an existing pension arrangement to us, we’ll keep personal information indefinitely.
If you get a quote or enquiry from us, but don’t go on to take out a pension product with us or transfer an existing pension arrangement to us, we’ll keep personal information for up to 6 months.
Savings and Investment Bond products - for example, Flexible Savings Plan, Tax-Free Savings Plan, Flexible Guarantee Bond.
If you take out a savings plan or an investment bond with us we’ll keep personal information for up to 20 years after the policy pays out.
If you get a quote or enquiry from us, but don’t go on to take out a savings plan or investment bond with us, we’ll keep personal information for up to 6 months.
Equity Release products - for example, Flexible Lifetime Mortgage, Lump Sum Lifetime Mortgage.
If you complete an application or take out a Lifetime Mortgage with us we’ll keep personal information for up to 100 years after the scheme ends.
If you get a quote or enquiry from us, but don’t go on to take out a Lifetime Mortgage with us, we’ll keep personal information for up to 6 months.
Your personal information rights
You have a right in certain circumstances to:
✔ access the personal information we hold about you
✔ correct personal information
✔ have your personal information deleted
✔ restrict us processing your personal information
✔ receive your personal information in a portable format, and
✔ object to us processing your personal information
You can also ask for a person to review an automated decision.
If you want to find out more or to exercise these rights please contact us: Life Customer Support, LV=, County Gates, Bournemouth, BH1 2NF or email us at: [email protected]
We’ll only send you marketing information about our products and services if you’ve given us permission. You can withdraw your consent at any time.
Your right to make a complaint
If you have a complaint about the way we process your personal data please contact us.
You can also raise your complaint with the Information Commissioner’s Office 0303 123 1113
or visit ico.org.uk/concerns
We may change this information from time to time. Any changes will be updated on our website and if appropriate notified to you in writing.