Privacy & Cookie Policy
Last update: 25th February 2019
By creating a profile on or using any of the Symphony Digital websites including, but not limited to www.petinsurancereview.co.uk (the "Website") you accept the terms contained in this Privacy Policy, which govern the processing of your personal data on the Website.
We are Symphony Digital Ltd trading as www.petinsurancereview.co.uk registered address: 7 Priory Court, Poulton, Cirencester, Gloucestershire, GL7 5JB (the "Website").
Our Data Protection Administrator can be contacted at: gdpr@petinsurancereview.co.uk
We will always comply (and be able to demonstrate our compliance) with relevant data protection legislation, including the Data Protection Act 2018 (“DPA”) and General Data Protection Regulation (“GDPR”) as applicable, when processing personal data. Further details on the DPA and GDPR can be found at the Information Commissioner’s Office website (www.ico.gov.uk).
PERSONAL DATA
When you write a review on www.petinsurancereview.co.uk, or leave a comment, we will retain the review and all the details it includes automatically. Your name will be displayed in the way you have chosen to give it to us. You can use your name or a nickname if you prefer.
When you leave a review on our websites, we collect the following information from you:
- Your Name (in the form you give it to us)
- Your email address
- Your pet’s details
- Your score out of 5 and views about the insurance company you are reviewing.
- Your IP address. We collect this as a way of verifying that each review is genuine and comes from separate individual with a separate IP address. We do not use IP addresses for any other purpose.
This information is mandatory, so you cannot leave a review without giving us this information. We display your name or nickname and your review. You can ask for us to remove your review or a comment you leave and all associated information at any time by emailing GDPR@petinsurancereview.co.uk.
When you request a quote through our quote form we will generate a personal account for you and collect the following personal data about you:
- Your Name (in the form you give it to us)
- Your email address
- Your postal address
- Your pet’s details
When you sign up to receive our newsletters or third party offers we will collect the following data from you:
- Your Name (in the form you give it to us)
- Your email address
Your pet’s details You can ask for us to remove your details from our database any time by emailing GDPR@petinsurancereview.co.uk. All personal quotes will be automatically deleted after 60 days from our systems. All newsletter and third party offer sign ups will be retained but you can unsubscribe at any time by emailing unsubscribe@petinsurancereview.co.uk.
We will act as the controller of personal data processed by use or on our behalf in connection with the Website or our other services.
We will collect and process personal data only to the extent that it is required for the specific purpose notified to the data subject, unless we are authorised by law to use the data for limited other purposes. We will not keep more personal data than necessary or for longer than necessary to achieve the purpose or purposes for which it was obtained. We will take all reasonable steps to erase from our systems all data which is no longer required.
We will take all reasonable steps to ensure that personal data we hold is accurate and up to date and to amend inaccurate or out-of-date data.
As the controller we will use the information you provide to us to:
- Provide our services to you, including displaying your reviews, sending your quote requests to selected pet insurance providers with your personal details including your email address for those insurers to contact you again, and providing you with access to your profile and our Website
- Verify your review is genuine
- Respond to your questions and provide related customer service
- Pass on a message from the company you reviewed via the Website comments
- Facilitate the social sharing function
- Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies
- Enforce our Terms & Conditions
- Allow us to pursue available remedies or limit any damages that we sustain
1. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?
We need to process your personal information in order to:
- Perform the services you have asked us to perform in our contract with you as stated in Article 6.1.b of the GDPR
- Perform any other business function with your specific consent which you are free to grant, withdraw or withhold at any time
- Exercise our legitimate business interests
- Comply with our legal obligations as stated in Article 6.1.c of the GDPR and operate an online review platform in compliance with, for example, the Competition and Markets Authority’s guidance on online reviews and endorsements
If you would like more information about our legal basis for processing your personal information, please contact our Data Protection Administrator by emailing gdpr@petinsurancereview.co.uk
2. DATA RETENTION
We keep the review data and other personal data you provide, for as long as you have a publicly published review. If you choose to delete your review or comment we will delete all personal data including your name, email address and the associated review or comment. If you would like your reviews or comments or personal information deleted, you can request this by emailing gdpr@petinsurancereview.co.uk.
If you complete a quote request and in doing so ask us to send your details to insurance companies so they can provide you with a quotation we will keep the details of your quote request for 60 days and then delete them. If you would like your details deleted sooner, you can request this by emailing gdpr@petinsurancereview.co.uk
We will send the insurance companies your personal details so they can prepare a quotation for you and your pet and then send you the quotation direct to your email address. We do not take any responsibility for the compliance with GDPR or the data processing undertaken by any of our partner insurance companies – please refer to their own privacy policies for further details. If you wish any of our insurance partners to cease emailing you at any time you must contact them directly to ask them to remove your details from their database.
If you sign up to be sent petinsurancereview.co.uk newsletters we will keep the details you give us on record. You can ask us to remove you from our mailing lists at any time by emailing unsubscribe@petinsurancereview.co.uk
2.1. ACCESS THE PERSONAL DATA WE HAVE ABOUT YOU
If you have requested a quotation or signed up to receive newsletters you can log in to your Account using your email address to see what information we have about you and your quote request.
If you have left a review or comment on our site, you can email gdpr@petinsurancereview.co.uk to request information. Upon receiving your request, we will let you know what personal information we have about you, how we collect the information, the purpose for which we process your personal data, and who we share your personal information with.
2.2. INFORMATION IN REVIEWS AND RATINGS
When you write a review about a company or product using our Website, we collect the information you put in your review and link it to the product or company being reviewed. We may contact you via email to provide information or documentation verifying your experience. If you write a company review on the Website in response to an invitation sent by a company, the company who sent you the invite will have visibility of the review and the personal data of the person writing the review.
2.3. COOKIES
Cookies are digital information which is stored on your computer. The cookie does not identify the individual user but the user's computer, and it is for example used for measuring Website traffic for the purpose of producing anonymous statistics in order to improve the functionality of the Website and to get the Website to work. You can read more about what cookies we use on the Website and for what purposes below.
2.3.1 THIRD PARTY COOKIES
We may provide cookie and anonymised data to trusted 3rd parties to improve the relevance of online advertising and personalisation.
Your email address is only shared with our 3rd party insurance partners if you request a quotation by completing our quotation request form. They will then email a quotation to you directly. Symphony Digital Ltd cannot be held responsible for how such third parties process your personal data – please refer to their own privacy policies for further details. Personal data is not otherwise shared with any other third parties at any time.
Third party Cookies are set by third party websites – not our Website. When you visit our Website, the following third party Cookies may be set:
- Google Analytics Cookies set when you log in to our Website with Google and used to help us to understand how people use and come to our Website
- Google AdSense cookies set when displaying relevant targeted advertisements on our Website.
- Third party vendors, including Google, use cookies to serve ads based on a user's prior visits to our website or other websites.
- Google's use of advertising cookies enables it and its partners to serve ads to our Website users based on their visit to our sites and/or other sites on the Internet.
- Some cookies may be set by DoubleClick, which is a tracking technology and part of Google.
2.3.2. DELETION OF COOKIES
You can delete the cookies already on your device. However, refusing to accept some or all of our cookies may affect your ability to access or use certain parts of the Website. You can typically delete cookies from the Privacy or History area, available from the Settings or Options menu in most browsers. Users may opt out of personalized advertising by visiting Ads settings or www.aboutads.info or Your Online Choices at http://www.youronlinechoices.com/uk/.
3. IP ADDRESSES AND BROWSER SETTINGS
When visiting the Website, the IP address of your computer or device is logged. The IP address is the numerical address of the computer or device used when visiting the Website and does not directly identify the user of that computer or device. The IP address is registered to analyse how visitors use the Website, to monitor users’ preferences whilst visiting the Website and to enable petinsurancereview.co.uk to trace the computer or device in case of misuse or unlawful actions in connection with the visit on or use of the Website. Further, the IP address is used to derive your approximate location (city level) and verify your review as genuine. IP data is removed after 30 days unless a review is written in which case the IP data is retained until the review is deleted or a removal request has been actioned.
4. DISCLOSURE TO OTHER SERVICES
Symphony Digital Ltd permits other services and companies being reviewed on petinsurancereview.co.uk to show their reviews created on the Website. However, we only share personally identifiable data with third parties as set out above.
4.1. OTHER DISCLOSURE
Symphony Digital Ltd may be required to disclose information by a court order from a competent court of law or public authority in accordance with the existing legislation. As a controller of personal data we allow the companies being reviewed to see contactable data provided by the reviewer, in a secure digital environment if requested to do so and in order to comply with a legal request from a competent court.
- SECURITY MEASURES
Symphony Digital Ltd will put in place appropriate procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor in accordance with equivalent procedures and policies. Symphony Digital Ltd regularly audits its system for possible vulnerabilities and attacks. However, since the internet is not a 100% secure environment, Symphony Digital Ltd cannot ensure or warrant the security of information you transmit to petinsurancereview.co.uk.
We may transfer personal data we hold to a country outside the UK or EEA (e.g. for storage in a secure cloud storage centre) where one of the following conditions applies:
(a) specific contractual clauses or binding rules are in place
(b) the data subject has given explicit consent
(c) the transfer is necessary for certain specified reasons such as: the performance of a contract, for reasons of public interest, for the purpose of a legal claim, to protect the data subject’s vital interests or for our legitimate interests.
- YOUR RIGHTS
We will process all personal data in line with data subjects’ rights, in particular their right to:
(a) access any personal data held about them
(b) be given certain information concerning how their personal data is obtained and processed (this information is as set out in this Policy)
(c) have their personal data rectified where necessary
(d) have their personal data erased in certain circumstances (the “right to be forgotten”)
(e) restrict processing of their personal data in certain circumstances
(f) have their personal data transferred to themselves or another data controller (“data portability”)
(g) object to automated processing
You may make formal requests for access to information we hold about you. All such requests will be forwarded to the Data Protection Administrator for a response within the applicable time period. We will only disclose personal data we hold once we have verified the enquirer’s identity to ensure personal data is only given to a person who is entitled to it.
- CORRECTION & DELETION
If you discover that the information which Symphony Digital Ltd holds on you on any of its Websites is incorrect or misleading, Symphony Digital will make any corrections on your request.
You can at any time correct or delete any content and information on the Website via your user profile or by contacting us at gdpr@petinsurancereview.co.uk. When your quotation account is deleted, all the data associated with your user profile is deleted. If you ask us to delete a review on the Website, the review will be permanently deleted.
Symphony Digital Ltd reserves the right to block the access to your profile and/or delete your profile, or reviews if the profile or the content of your profile or reviews on the Website in our assessment is discriminating, racist, sexually oriented, unethical, threatening, offensive, harassing or in other ways violates the legislation, third party rights or the purpose of the Website. If we block the use of your profile, you shall be informed with the reason for blocking the access, by email to the address you have stated in your profile.
8. BANK & CREDIT CARD INFORMATION
If you have written a review, we do not need any private banking details from you. The only details we ask for are a name and email address to confirm that you are a real user. We will never gain access to your credit card number. If you do choose to purchase something by clicking through to one of our retailers, we will not see any of your private information including banking details or credit card numbers.
9. AGE REQUIREMENTS - 18 OR OLDER
We require our users to be 18 or older and anyone using the site must adhere to this rule. We never knowingly allow children under 18 to post personal information on our site. If you know about someone using the website under the age of 18 please contact us via gdpr@petinsurancereview.co.uk.
10. LINKS TO EXTERNAL WEBSITES
Our Website contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third- party websites and assume no responsibility for the third party or their policies or practices.
11. CHANGES IN THE PRIVACY POLICY
Symphony Digital Ltd may at any time and without notice make changes to this Privacy Policy with future effect. You agree that the continued use of the Website after any posted modified version of the Privacy Policy is your acceptance of the modified Privacy Policy.
13. ENQUIRIES REGARDING THIS PRIVACY POLICY
If you have any questions or comments, or if you want to update, delete, or change any Personal Information you've submitted on the Website, please use our contact form to get in touch.
In addition, you are welcome to contact our Data Protection Administrator if you have any questions about the data processing activities performed by us gdpr@petinsurancereview.co.uk or by post at this address:
Symphony Digital Ltd 7 Priory Court, Poulton, Cirencester, Gloucestershire GL7 5JB.