PRIVACY NOTICE

Scottish Widows Europe

Last updated on May 2021

How we use your personal information

Your information will be held by Scottish Widows Europe S.A. (www.scottishwidowseurope.com) which is part of Lloyds Banking Group. This privacy notice is to let you know how Scottish Widows Europe S.A. as a company within the Group promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer. This notice also tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

  • To keep your data safe and private.
  • Not to sell your data.


Personal information and the law

This section tells you who we are, what your personal information is, and how we get it. It explains how the law protects you by controlling what is allowed to happen to it.

The control you have

This section covers how to complain or withdraw your consent. It also tells you how you can get a copy of your personal information, or ask for it to be changed or removed.

How personal information is used

This tells you who we share personal information with. It explains what it's used to combat fraud - and how this can affect you.


Personal information and the law

Who we are

This section gives you the legal name of the company which holds your personal information – known as the ‘legal entity’ – and tells you how you can get in touch with us. Scottish Widows Europe S.A. is the legal entity and data controller who holds and is responsible for looking after your personal information.

Scottish Widows Europe S.A. is part of the Lloyds Banking Group. Lloyds Banking Group is made up of a mix of companies, set up on different legal entities. We'll let you know which you have a relationship with, when you take out a product or service with us.

You can find out more about us at www.scottishwidowseurope.com


Contacting us about data privacy

Please use these details to contact us about any of the topics set out in this Privacy notice.

If you have any questions, or want more details about how we use your personal information, you can write to us at

Scottish Widows Europe S.A.
Europe Building,
1, Avenue du Bois,
Limpertsberg, L-1251 Luxemburg
Email: DPO@scottishwidowseurope.com


How the law protects you

This section sets out the legal reasons we rely on, for each of the ways we may use your personal information.

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data protection law (including, amongst others, the General Data Protection Regulation (GDPR) and data protection law applicable in local jurisdictions, such as in Luxembourg the law of 1 August 2018 on the organisation of the National Commission for Data Protection) says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing with Lloyds Banking Group and its external service providers. The law says we must have one or more of these reasons:

  • To fulfil a contract we have with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest, or
  • When you consent to it.

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

  • To establish, exercise or defend legal claims.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.


What we use your personal information for: Our reasons Our legitimate interests

1. Serving you as a customer

  • To manage our relationship with you or your business.
  • To communicate with you about our products and services.
  • To develop and manage our brands, products and services.

  • Your consent
  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

  • Keeping our records up to date, working out which of our products and services may interest you and telling you about them.
  • Developing products and services, and what we charge for them.
  • Seeking your consent when we need it to contact you.
  • Being efficient about how we fulfil our legal and contractual duties.

2. Business improvement

  • To manage how we work with other companies that provide services to us and our customers.

  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

  • Developing products and services, and what we charge for them.
  • Being efficient about how we fulfil our legal and contractual duties.

3. Managing our operations

  • To deliver our products and services.
  • To make and manage customer payments.
  • To manage fees, charges and interest due on customer accounts.
  • To collect and recover money that is owed to us.

  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

  • Being efficient about how we fulfil our legal and contractual duties.
  • Complying with rules and guidance from regulators.

4. Managing security, risk and crime prevention

  • To detect, investigate, report, and seek to prevent financial crime.
  • To manage risk for us and our customers.
  • To obey laws and regulations that apply to us.
  • To respond to complaints and seek to resolve them.

  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

  • Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect.
  • Complying with rules and guidance from regulators.
  • Being efficient about how we fulfil our legal and contractual duties.

5. Business management

  • To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, adding and testing systems and processes, managing communications, corporate governance, and audit.

  • Our legitimate interests
  • Our legal duty

  • Complying with rules and guidance from regulators.
  • Being efficient about how we fulfil our legal and contractual duties.

  • To exercise our rights set out in agreements or contracts.

  • Fulfilling contracts

6. For processing special categories of personal information

  • Using criminal records data to help prevent, detect, and prosecute unlawful acts and fraudulent behaviour (as authorised by applicable local laws).
  • Using criminal and health information as needed to provide insurance products (as authorised by applicable local laws).

  • Responding to regulatory requirements

  • Showing whether we have assessed your situation in the right way.
  • Passing information to the regulator as needed to allow investigation into whether we have acted in the right way.

  • Legal claims

  • Using any special categories of data as needed to establish, exercise or defend legal claims.


Groups of personal information

This explains what all the different types of personal information mean, that are covered by data protection law.

We use many different kinds of personal information. They are grouped together like this. The groups are all listed here so that you can see what we may know about you. We don’t use all this data in the same way. Some of it is useful for providing services to you. But some of it is private and sensitive and we treat it that way.

Type of personal information Description
Financial Your financial position, status and history.
Contact Your name, where you live and how to contact you.
Socio-Demographic This includes details about your work or profession, nationality, education and where you fit into general social or income groupings.
Transactional Details about payments to and from your accounts, and insurance claims you make.
Contractual Details about the products or services we provide to you.
Communications What we learn about you from letters and emails you write to us, and conversations between us.
Social Relationships Your family, friends, and other relationships.
Open Data and Public Records Details about you that are in public records such as your local electoral register, and information about you that is openly available on the internet.
Documentary Data Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, driving licence, or birth certificate.
Special categories of data

The law and other regulations treat some types of personal information as special. We will only collect and use these if necessary and if the law allows us to do so:

  • Religious data (e.g. German & Austrian church tax info)
  • Health data
  • Lifestyle information

You can read how we may use special types of data in the table ‘How the law protects you’.

Personal data relating to criminal convictions and offences

We will also only process the following categories of data if the law allows or requires us to do so:

  • Criminal records of convictions and offences
  • Allegations of criminal offences.
Preferences Any preferences that you give us. This includes things like how you want us to contact you, whether you get paper statements, or if you prefer large-print formats.
National Identifier A number or code given to you by a government to identify who you are, such as a National Insurance or social security number, or Tax Identification Number (TIN).

Where we collect personal information from

This section lists all the places where we get data that counts as part of your personal information.

We may collect personal information about you (or your business) from other Lloyds Banking Group companies and any of these sources:

Data you give to us

This covers data given by you as well as data provided by people linked with you or your business’s product or service, or people working on your behalf. This could mean a joint account holder, trustee, or fellow company director.

  • When you apply for our products and services
  • When you talk to us on the phone, including notes we make
  • In emails and letters
  • In insurance claims or other documents
  • In financial reviews and interviews


Data we collect when you use our services

This covers: details about the account activities that are shown on your statement.

  • Payment and transaction data
    This includes the amount, frequency, type, location, origin and recipients.


Data from outside organisations

  • Companies that introduce you to us (if you use a broker)
  • Financial advisors
  • Credit reference agencies
  • Insurers
  • Fraud prevention agencies
  • Other financial services companies (to fulfil a payment or other service as part of a contract with you, or to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)
  • Employers (for instance, Employment details for a Pension Product)
  • Payroll service providers
  • Public information sources such as your local electoral register or commercial register of companies
  • Agents, suppliers, sub-contractors and advisers
    These can be types of firms we use to help us run accounts and services. They can also be specialist companies who advise us on ways to develop and improve our business.
  • Firms providing data services (We receive reports that we use to better understand our customers and look for general patterns and trends.
  • Medical professionals (for some insurance products, we may ask your GP or other medical practitioner to send us a report. We will only do this if we get your consent first)
  • Government and law enforcement agencies.


How long we keep your personal information

This section explains how long we may keep your information for and why

We will keep your personal information for as long as you are a customer of Scottish Widows Europe S.A. as part of the Lloyds Banking Group.

We may keep your data for up to 10 years after you stop being a customer, depending on the type of data. The reasons we may do this are:

  • To respond to a question or complaint, or to show whether we gave you fair treatment.
  • To study customer data as part of our own internal research.
  • To obey rules that apply to us about keeping records (for example Articles 14, 16 paragraph 2 and 189 of the Luxembourg Commercial Code).

We may keep certain types of data for shorter periods. For example, Money Laundering regulations in Luxembourg require us to retain certain data for 5 years after you stop being a customer.

We may also keep your data for longer than 10 years if we cannot delete it for legal, or regulatory reasons. As an example, we have to hold pension transfer information indefinitely; and in cases of other legal claims we will keep any associated data until the claim has reached its conclusion.

We will only use your personal information for those purposes and will make sure that your privacy is protected.


If you choose not to give personal information

You can choose not to give us personal information. In this section we explain the effects this may have.

We may need to collect personal information by law, or to enter into or fulfil a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from fulfilling our contract with you, or doing what we must do by law. It may also mean that we cannot run your accounts or policies. It could mean that we cancel a product or service you have with us.

We sometimes ask for information that is useful, but not required by law or a contract. We will make this clear when we ask for it. You do not have to give us these extra details and it won't affect the products or services you have with us.


Cookies

This section contains a link to our Cookies Policy

Cookies are small computer files that get sent down to your PC, tablet or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from, when you go there again. Cookies store information about your visits to that website, such as your choices and other details. Some of this data does not contain personal details about you or your business, but it is still protected by this Privacy notice.

To find out more about how we use cookies, please see our Cookies Policy


The control you have

How to complain

This section gives details of how to contact us to make a complaint about data privacy. It also shows you where you can get in touch with the government regulator.

Please let us know if you are unhappy with how we have used your personal information. You can contact us at the details shown above in the “contacting us about data privacy” section

You also have the right to complain to the regulator, and to lodge an appeal if you are not happy with the outcome of a complaint.

In Luxembourg, you may do this either by filling in an online complaint form available on the CNPD Website https://cnpd.public.lu/fr/particuliers/faire-valoir/formulaire-plainte.html, or by sending a letter addressed to the Commission Nationale pour la Protection des Données, Service des Réclamations, 1, avenue du Rock'n'Roll, L-4361 Esch-sur-Alzette, Grand-Duchy of Luxembourg.

If you reside in another EU member state, you have the right to lodge your complaint with your local data protection supervisory authority.


How to withdraw your consent

This section explains what to do if you change your mind about a consent you have given.

You can withdraw your consent at any time. Please contact us at the details above if you want to do so.

This will only affect the way we use information when our reason for doing so is that we have your consent. See the section 'Your Rights' about more generally restricting use of your information.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.


Letting us know if your personal information is incorrect

Here you can find out how to contact us if you think the information we hold for you is wrong, incomplete or out of date.

You have the right to question any information we have about you that you think is incorrect. We’ll take reasonable steps to check this for you and correct it.

If you want to do this you please contact us at the details above.


How to get a copy of your personal information

This section tells you where to write to us to get a copy of your personal information, and how to ask for a digital file you can use yourself or share easily with others. You can get a copy of all the personal information we hold about you by contacting us at the details above.


When you want to share your data with outside companies

You also have the right to get certain personal information from us as a digital file, so you can keep and use it yourself, and give it to other organisations if you choose to. If you wish, we will provide it to you in an electronic format that can be easily re-used, or you can ask us to pass it on to other organisations for you.

If you want to do this, please contact us at the details above.


Your rights

What if you want us to stop using your personal information? This section explains about your right to object and other data privacy rights you have – as well as how to contact us about them.

You can object to us keeping or using your personal information. This is known as the 'right to object'.

You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the 'right to erasure' or the 'right to be forgotten'.

There may be legal or other official reasons why we need to keep or use your data to some extent. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights.

You can ask us to restrict the use of your personal information if:

  • It is not accurate
  • It has been used unlawfully but you don’t want us to delete it
  • It is not relevant any more, but you want us to keep it for use in legal claims
  • You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

If we do restrict your information in this way, we will not use or share it in other ways while it is restricted.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it please contact us at the details above.


How personal information is used

Who we share your personal information with

We may share your personal information with outside organisations such as insurers or tax authorities. This is so that we can provide you with products and services, run our business, and obey rules that apply to us. Here we list all the types of organisation that we may share your personal information with.


Lloyds Banking Group

We may share your personal information with other companies in Lloyds Banking Group. For example, Scottish Widows Europe S.A. will share certain data with Scottish Widows Limited in the UK. Scottish Widows Europe S.A. also has foreign branches in Germany and Italy, which receive and share data with other entities within Lloyds Banking Group.


Authorities

This means official bodies that include:

  • Central and local government
  • Administration des contributions directes, the tax authority in Luxembourg
  • Commissariat aux Assurances, the Luxembourg regulator for insurance companies
  • Other regulators and tax authorities
  • Law enforcement and fraud prevention agencies.


Banking and financial services

Outside companies we work with to provide services to you and to run our business.

  • Agents, suppliers, sub-contractors and advisers
    These are types of firm that we use to help us run accounts, policies and services. For example, Scottish Widows Europe S.A. and its branches in Germany and Italy are supported by service providers in Germany, Austria, Italy and Luxembourg.
  • Agents who help us to collect what is owed to us
  • Credit reference agencies
  • Someone linked with you or your business’s product or service.
    This could mean a joint account holder, trustee, or fellow company director.
  • Other financial services companies (to fulfil a payment or other service as part of a contract with you; or to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)
  • Independent Financial Advisors (if you have one)
    This could be someone who you, your employer, or product owner have selected to advise on things like pensions or life assurance.
  • Employers


Insurers

We share personal information with insurance industry companies to process claims and help reduce fraud. We do that in these ways:

  • If you apply for insurance through us, we may pass your personal or business details to the insurer.
  • If you apply for insurance with us as the insurer, we may share your personal or business details with reinsurers.
  • If you make an insurance claim, information you give to us or the insurer may be put on a register of claims. This will be shared with other insurers, our agents, suppliers and sub-contractors. In some cases we may also share it with our business partners, if you also have a relationship with them.


Other services and schemes

These are organisations that we may need to share your personal information with, because of what you can do with the product or service you have with us.

  • If you use direct debits, we will share your data with the relevant Direct Debit scheme.

If you have a product with benefits such as travel insurance or discount offers, we will share your data with the benefit providers. We may also share it with other companies involved in how you use the


Company mergers, takeovers and transfers of products or services

We may also share your personal information if the ownership of products or services or the make-up of Lloyds Banking Group changes in the future

  • We may choose to sell, transfer, or merge parts of our business, or our assets, including products or services. Or we may try to bring other businesses into Lloyds Banking Group.
    This is sometimes called Mergers & Acquisitions or 'company takeovers'.
  • During any such process, we may share your data with other parties involved. We’ll only do this if they agree to keep your data safe and private and the data subject would be informed at the appropriate time during this process.
  • If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.


Sharing data that does not say who you are

We may share or sell some data to other companies outside Lloyds Banking Group, but only when it is grouped so that no-one’s identity can be known or found out.


How we use your information to make automated decisions

Scottish Widows Europe S.A. do not rely on automated decision making by our systems.


Credit Reference Agencies (CRAs)

This section explains what we do and why we do it.

We may work with Credit Reference Agencies in some limited circumstances to carry out affordability and identity checks when changes are made to your policy. For example, if there is a significant increase to your existing contributions or if there is a change of policyholder, we may request a CRA to carry out credit and identity checks.


Fraud prevention agencies

This section deals with information we share outside our group to help fight financial crime. This includes crimes such as fraud, money-laundering and terrorist financing.

We may need to confirm your identity before we provide products or services to you or your business. This may include carrying out fraud checks at the point of sale.

Once you have become a customer of ours, we will share your personal information as needed to help combat fraud and other financial crime. The organisations we share data with are:

  • Registered Fraud Prevention Agencies (FPAs)
  • Other agencies and bodies acting for the same purpose
  • Industry databases used for this purpose
  • Insurers

Throughout our relationship with you, we and these organisations exchange data between us to help prevent, deter, detect and investigate fraud and money-laundering.

None of us can use your personal information unless we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

We will use the information to:

  • Confirm identities
  • Help prevent fraud and / or money-laundering
  • Fulfil any contracts you or your business has with us.

We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to prevent, detect, investigate and prosecute crime.

These other organisations can keep personal information for different lengths of time, up to six years.


The information we use

These are some of the kinds of personal information that we use:

  • Name
  • Date of birth
  • Residential address
  • History of where you have lived
  • Contact details, such as email addresses and phone numbers
  • Financial data
  • Whether you have been a victim of fraud
  • Data about insurance claims you have made
  • Data relating to your or your businesses products or services
  • Employment details


How this can affect you

If we or an FPA decide there is a risk of fraud, we may stop activity on the accounts or block access to them. FPAs and cross-industry organisations may also keep a record of the risk that you or your business may pose.

This may result in other organisations refusing to provide you with products or services, or to employ you.


Data transfers out of the EEA (this may include the United Kingdom after 01/01/2021)

FPAs and other organisations we share data with for these purposes may send personal information to countries outside the European Economic Area (‘EEA’). When they do, there will be a contract in place, before the transfer, to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.


Sending data outside the EEA (this may include the United Kingdom after 01/01/2021)

This section tells you about the safeguards that keep your personal information safe and private, if it is sent outside the EEA.

We will only send your data outside of the European Economic Area (‘EEA’) to:

  • Follow your instructions.
  • Comply with a legal duty.
  • For example, we share information about US citizens with the US tax authority.
  • Work with our suppliers who help us to run your accounts and services.
  • For example, Lloyds Banking Group entities, including Scottish Widows Europe S.A. and Scottish Widows Limited, work with an IT supplier in India to whom limited data is sometimes transferred for this reason.
  • Transfer the data to an entity within Lloyds Banking Group, for example to Lloyds Bank plc or Scottish Widows Limited in the UK.

If we do transfer your personal information outside the EEA to our suppliers, we will make sure that it is protected to the same extent as in the EEA. We’ll use one of these safeguards:

  • Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
  • Put in place a contract with the recipient such as the EU Standard Contractual Clauses approved by the European Commission which means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website.
  • Scottish Widows Europe in line with Lloyds Banking Group policy, carry out due diligence with our third party suppliers, to ensure the same standards of data protection and security are in place to meet EEA guidelines.

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