The main purpose for which we process your personal data is to provide you with services that you request from us at www.iCompare.lu(the Website). We may need some information from you about health or criminal convictions to do this. We cannot display quotes for certain types of insurance (such as life insurance or vehicle insurance) without this data. We will also process personal data for other purposes, such as marketing (where you have consented), market research and fraud prevention. We will only ever keep your personal data for as long as is necessary for the purpose for which we need that personal data.
We will need to share some of your personal data with some third parties, for example our partners and suppliers. Partners who provide quotes to you through our website will make checks against various databases to assess your eligibility for a quote and will make decisions about you by wholly automated means. Those partners are responsible for how they process your personal data. You can view a list of the partners that we work with by clicking here.
Who is processing your data?
We are iCompare.lu and we are the data controller of the personal data that you provide on the Website and/or that we collect about you. This means that we are the company responsible for deciding how your data is processed.
iCompare.lu is part of iCompare Global Sàrl, a company registered under Luxembourg Law with its headquarters at 64-68 rue de Luxembourg, L-8140, Bridel, Grand-Duchy of Luxembourg.
Car, Home, Health Insurance and Financial Protection
Where do we get the data from?
Most of the data that we process will be data that we collect from you directly when you request a quote. We will ask you various questions to collect the data we need for the purpose of providing quotes and comparison information. We will not be able to provide a quote unless you answer the mandatory questions. Where questions are optional, we will explain what we need the data for.
From our insurance partners
We will also obtain certain personal data about you from the insurance partners on our panel if you take out an insurance policy with them through our Website. This will include information about whether or not you took out a policy with the insurance partner and the type of policy. We use this information to track sales as well as improve our Website, our services and our customer journey. If there are any complaints or queries about your quote or your policy, we and the relevant insurance provider(s) will also exchange information about the complaint or query to ensure it is appropriately investigated and dealt with.
From your use of the Website and our services
We also collect data about you based on your actions, for example we collect data about how and when you use the Website so that we can build up a picture of you as a customer. This can include information such as how many quotes you have obtained for insurance, mouse clicks/taps, mouse movements, page scrolling and text entered into forms which we collect through software which monitors how customer use our Website. This helps us to provide you with a good service and to design improvements to our products and services (including changes to our website) but is also used to help us to prevent and detect fraud.
Providing data about other people
What do we use your data for?
The data that we hold is used for the following purposes:-
Part 1 - Providing you with our services
The personal data that we use for the purposes set out in this Part includes: your name, contact details, date of birth, address history, driving history, claims history, any previous convictions, details about your vehicle and/or your home and belongings, details about your relationship, information about your employment and income, identification information and your no claims history.
Providing you with a service and administering your account.
We use the data set out above to:
· provide you with the insurance and financial products comparison services you request from us (which includes both sharing information with our product providers and our comparison service partners who collect and share your information as set out under "Who is processing your data" above);
· send you any reminders that you have set up
· automatically generate quotes when your policies are due for renewal if you have opted into this service (you can opt out of this service at any time by changing the settings in your account)
· store your documents if you use the "Login" feature, we also carry out analysis of your documents to identify the key information from the documents to make it easier for you to find the information you need; communicate with you about our services, for example send you confirmation emails regarding your quotes or your account details.
· manage, run and administer your account if you choose to set up an account with our Website; and
· help us build up a picture of you as a customer to ensure that we provide you with more relevant information, such as showing you the right content at the right time.
Data protection law says that we have to tell you the legal basis on which we process your personal data. In relation to personal data used for providing you with a service and managing your account, we process this data because it is necessary to perform the contract that we have in place with you to provide you with our services.
Part 2 – Fraud Prevention
Inorder to prevent and detect fraud we and/or our partners and/or comparison service partners may use the personal data set out above at any time to:
1. Check and/or share your details with fraud prevention and detection agencies; and
2. Share information about you with other organisations including the police, where necessary and proportionate; and
3. Carry out analysis on data that is held in order to assist the identification of Fraud.
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.
In relation to the personal data processed for fraud prevention, we process this we have a legitimate business interest in carrying out these activities to help minimise the risk of fraud or crime occurring and in its detection.
Part 3 – Other Uses of Data
When you provide your details you will be given an opportunity to confirm whether you are happy to receive marketing material from us. If you confirm you are happy to receive this material, we will use your postal address, email address and telephone number to send you marketing materials by post, email, telephone call or SMS. We do not pass your data to other companies for marketing purposes.
If you consent to us contacting you for marketing purposes, we will disclose an anonymised version of your email address (we use a process called hashing to protect your details) to third party social media sites such as Facebook to enable us to display marketing to you via such sites. "Hashing" is similar to encryption and means that we scramble the plain text of your email address to create a unique and irreversible message. This means that the social media sites do not receive a plain text version of your email address. Where we do this, we require social media providers only to use your information for the purposes of enabling us to display marketing to you through their site and not for any of their own purposes.
You can change your mind at any time by logging into your account and updating your preferences. You can also unsubscribe from emails by clicking on the unsubscribe link on any marketing emails that we send you, updating your preferences in your account or by emailing firstname.lastname@example.org
This will not impact any communications that we need to send you for the purpose of your quote, for example confirmation of your quote or your account details, notifications we need to send you regarding any rewards you have claimed or communications necessary for any other services you have requested that we provide to you.
From time to time we may want to use your postal address, email address and/or telephone number to contact you to assist us with our research by asking you a few questions about the service you have received or by asking if you would like to complete a review of our services. We may sometimes ask market research companies to contact you on our behalf.
If you would prefer us not to contact you for market research purposes then you can let us know by contacting us at email@example.com
Research and Analysis Activities
We and our partners use data relating to your quotes, including the personal data you input to request your quotes and information about the policies or contracts you have taken out, to carry out various research and analysis activities to help us to regularly review and improve the products and services we or our partners provide and carry out research. We also share this data with our insurance providers and comparison service providers to enable them to use this data for these purposes. Where possible, data will be shared on an anonymised basis. The data will not be used to make any decisions that will affect you or any other individual and we require our partners and comparison service providers to delete the data as soon as the relevant research and analysis activity is concluded.
We also use the data that we collect about you through your Website usage to carry out research and analysis into usage and activities on our Website to enable us to continue to improve our Website and our products and services.
In relation to personal data used for the purposes described in this Part 2, we process this data because we have a legitimate business interest in carrying out these activities to promote and improve our business. We have ensured appropriate safeguards to protect your rights when processing this data for these purposes.
How long do we keep data?
We'll only keep your personal data as long as we need it and ensure it is securely destroyed when it is no longer required. We do however need to keep certain data after we have provided you with your quotes for certain periods as detailed below.
Generally, you can expect us to keep your data for a period of 5 years from when you obtain your quote. If you have an account with us we will keep your data while your account with us is active and then if you stop using your account we will generally retain your data for a period of 5 years from that point (unless there is a requirement for us to keep the data for longer, for example if there are any ongoing queries or claims relating to your quotes).
We keep data for these periods as it plays an important part in allowing us to undertake fraud detection and prevention activities, allows us to deal with any queries or complaints that may arise regarding quotes that have been provided and allow us to carry out research and analysis to help us improve our products and services (as described in the section headed "What do we use your data for?" above).
If you use the ‘Login’ facility we will keep your documents for a period of 5 years from the date you last used the account as described above.
Overseas transfer of data
We use third party suppliers to process limited personal data about you. Some of these suppliers may be located in countries outside of Luxembourg which may not have equivalent laws in place to protect your personal data. For example, we use third party software suppliers such as Microsoft to process data such as your email address, which Microsoft stores in the USA.
Our insurance providers and comparison service providers may also process personal data in countries outside of Luxembourg which may not have equivalent laws in place to protect your personal data. Our insurance partners and comparison service partners are the data controllers in respect of any such processing and such processing will be subject to their own Privacy Policies. We do not have any control over whether our partners or comparison service partners process personal data outside of Luxembourg but if this do this they must do it in accordance with data protection legislation.
Data protection law gives you various rights in relation to your personal data. All the rights set out below can be exercised by contacting us using the contact details set out under the "Contacting us" section below. Please note that we can only deal with requests to exercise these rights where they relate to personal data that we process as data controller. If you send us a request which relates to personal data processed by one or more of our partners or comparison service providers as data controllers, we will direct you to the appropriate insurance partner(s) or comparison service provider(s).
Your rights include:-
· You have the right to ask us to provide a copy of the personal data that we hold about you. This is called a Data Subject Access Request or "DSAR". You can access information about your quotes by logging into your account. If you want to receive other personal data that we hold then you can make a DSAR. When contacting us please describe the information you require and make sure that you tell us any email addresses you or anyone else have used to obtain quotes with us as this allows us to trace all relevant information. Please also include the following: your full name, your date of birth and your full address. For security purposes we can only deal with requests where the contact details you provide match the details we have on file and we may need to ask you for further information to verify your identity. If you have changed your contact details or you require information sending to different contact details please include a copy of your passport or driving licence and proof of address such as a recent utility bill to assist us in verifying your identity. We might also need to ask you for additional information to help us locate the data that you are looking for. Once we have all the information that we need to process your DSAR, we will respond within one month unless your DSAR is very large or complex, in which case we may need to extend this period. If we need to do this we will let you know. If you want to make a DSAR in relation to personal data that is held by any of our insurance partners then you will need to contact them directly.
· You have the right to ask us to correct inaccurate personal data that we hold about you. If you think any of your personal data is inaccurate, please contact us and, provided we can verify your identity and are satisfied as to the accuracy of the correction requested, we will correct the relevant personal data as soon as we can. You can also amend inaccurate data in your account.
· You have the right to request that we provide a copy of your personal data in a machine readable format or to ask us to send your personal data to another company. This applies to personal data that you have provided to us, which we have processed electronically, such as personal data you entered on our website when you obtained a quote.
· You also have the right to ask us to delete personal data that we hold about you. We are obliged to delete personal data in some circumstances, such as where it is no longer needed. However, data protection laws allow us to keep the personal data if we need to, for example if the data is needed for fraud prevention. In any case, we will retain your personal data in line with the retention periods detailed under "How long do we keep data?" above.
· You have the right to ask us not to do anything with your personal data except store it in limited circumstances, such as if you and we do not agree on the accuracy of personal data and steps are required to validate it.
· You have the right to object to us processing certain personal data about you. However, where we need to continue to process the personal data, for example for fraud prevention purposes, we are not obliged to stop processing it.
· You have the right to ask for significant decisions that have been made about you wholly by automated means to be reviewed. We do not make any significant decisions about you wholly by automated means. However, the nature of the quotes provided by our insurance partners means that they have to use this kind of automated decision making to assess your quotes. If you want any wholly automated decisions in relation to your quotes to be reviewed, you will need to contact the partner who has
produced the relevant quote.
If you would like to contact us about one of your data rights set out under "Your Rights" above, then please contact firstname.lastname@example.org write to Data Requests – 64-68 rue de Luxembourg, L-8140, Bridel, Grand-Duchy of Luxembourg.
- Voyager Insurance Services Ltd (UK)
- DKV Luxembourg