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Privacy Policy

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Llama Life and/or its agents or subcontractors respects your right to privacy. This privacy and cookie policy sets out details of the information that we may collect from you and how we may use that information.

Scope

This policy applies to the Llama Life Rewards Package and services provided by Llama Life and/or its agents or subcontractors and used by you, the customer, via the Rewards Website and our website Llamalife.co.uk.

Llama Life has partnered with Cignpost Life, in order to provide life insurance cover, and Xexec to provide you with the Rewards Package. Llama Life is the data controller which collects your personal data and passes it to these parties in order to provide you with the agreed services. In this Privacy Policy, references to “we”, “us” or “our” is a reference to Llama Life, however the policy covers how your data is handled by all parties.

Llama Life: “Llama Life” is a trading name of Primas Life Ltd.

Primas Life: Primas  Life means PRIMAS LIFE LIMITED, a company incorporated in England with registered number 11914600 with registered office at 6-7 Hammet Street, Taunton, Somerset, England, TA1 1RZ.

Cignpost Life: Cignpost Life is a trading style of Albany Park Limited, which is incorporated in England and Wales with the registered number 04296341 with registered office at Building X92, Cody Technology Park, Old Ively Road, Farnborough, Hampshire, GU14 0LX.

Xexec: Xexec means Xexec Limited which is incorporated in England and Wales with the registered number 04009440 with registered office at 88 Crawford Street, London, W1H 2EJ

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Your privacy

This Privacy Policy is meant to help you understand what data we collect, how we use that data and the choices we offer you, including how to access and update information.

We will at all times only collect and process your personal information in accordance with the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any other applicable data protection legislation.

Llama Life and/or its agents or subcontractors ensures that your personal data is processed in accordance with relevant laws, including the Principles of Data Protection set forth in Schedule 1 of the UK Data Protection Act. At no time will we trade, sell, or distribute your personal information to any individual, company, vendor or organisation, in ways other than disclosed in this privacy statement. If you have any questions or concerns regarding our privacy practices please contact us through one of the methods described below.

Your consent

By using this website you are acknowledging that you have read this policy and are consenting to the practices described here, including the transfer of your personal data outside the European Economic Area (EEA). By agreeing to this privacy and cookie policy you give your consent for us to do so.

Information we collect

On Our Website

We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contact from you.

Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services, or changes to this privacy policy.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:

(a) analytics & tracking providers some such as Google based outside the EU;

  • Google Tag Manager
  • Google Analytics
  • WordPress
  • YouTube
  • Facebook

(b) advertising networks based inside & outside the EU;

  • Google Adwords
  • Bing Ads
  • Google Display Network
  • PPC Protect
  • Facebook ads
  • Instagram
  • Twitter
  • Linkedin.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Credit Card Authorisation based inside the EU.
  • Third party software and applications where you are given the choice to share data with us:
  • Websites promoting protection insurance.
  • From Medical practitioners:
  • Where it is necessary to obtain medical details for claims handling purposes and we will always request your consent to do so.
  • From identification and verification checking agencies:
  • Identity information
  • Anti-money laundering and sanction check information.

In the course of our services for insurance, we will collect the following personal data when you provide it to us:

  • contact information
  • identity information
  • payment information
  • lifestyle information
  • health information
  • details of any vulnerability
  • product details
  • profile information
  • evidence of consent.

In Our Rewards Package

We collect information for authenticating your right to use the rewards, optimising your experience, conducting financial transactions, tracking your transaction activity at retailers, and providing you with customer service. We will not collect information that is irrelevant to the purpose of providing you with access to or use of this website. We collect the following information:

Essential information that you may give us or may be given to us by your organisation in order for you to use this rewards package may include – first name, last name, email address, and postal code. By using this rewards package, you are giving us consent to use it as set out in this Privacy Policy.

  • Additional personal information – you can decide to provide us with additional information that will allow you to use additional functionality on this rewards package.
  • Additional information provided by you may include:
    • Preferences and reminders
  •  
    • Home Address
    • Telephone number
    • Mobile phone number
    • Date of birth
    • Payment and bank account information
    • Automatically generated logging information created while you use the rewards package may including:
    • Transactional information
    • Customer service inquiries
    • Points activity
    • Clickstream information
    • Cookies
    • Shopping activity information like, e-codes, and cinema codes created as a result of using this website

How we use the information

We use the information we collect for the following purposes:

We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organisation, other than as necessary to fulfil your request, e.g. to arrange a life insurance policy.

Essential information, which may include name, email, and postal code is used to authenticate you with a unique account, communicate with you and enable you to access the benefits and services of the Rewards Website.

Additional information obtained from you is used to facilitate additional functionality, provide relevant offers and fulfil transactions.

Information generated while on the site is used by Llama Life and/or its agents or subcontractors to protect you, provide you with customer service, prevent fraud, operate this rewards package, affect session management and respond to your requests.

You are applying for a Cignpost Life Policy, insured and administered by iptiQ Life S.A. Both iptiQ and Albany Park Ltd will be handling the personal information you provide to them for their respective purposes. This includes any sensitive personal data such as health information which you provide as part of the application process.

iptiQ Life S.A will only handle your personal information where you purchase a policy.

Albany Park Ltd and / or iptiQ may use personal information for the following purposes. The below table sets out:

  • how we use your personal data
  • the lawful bases upon which we collect and use your personal data.

Rationale/Reason for Processing

Lawful Basis for Processing

Third party recipients linked to that activity

to provide you with quotations for protection insurance products on your behalf to apply for products on your behalf

Performance of a contract

Our partner organisations.

to assist in the administration of any products you have obtained through us

Performance of a contract

Our partner organisations.

to manage complaints

Compliance with a legal obligation

Our partner organisations. Our external solicitors

to manage legal claims

Legitimate interests we have a legitimate interest in protecting ourselves from breaches of legal obligations owed to us and to defend ourselves from litigation. This is needed to ensure that our legal rights and interests are managed appropriately

Our partner organisations. Our external solicitors

to obtain feedback from you on the service you have received from us

Legitimate interests we have a legitimate interest in operating our business. This includes ensuring that the service we provide is of a satisfactory standard

External supplier(s) of software services to obtain feedback from you – Trust Pilot, Feefo

to retain records of any services or advice provided to you in accordance with our regulatory obligations. Call recordings maybe used.

Compliance with a legal obligation

External supplier(s) of data storage and data hosting services to retain records on our behalf Our Parent companies

to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Our partner organisations. Delta PC

to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Our partner organisations. Advertising networks such as Facebook Google Adwords Bing Ads & Others

to use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Our partner organisations. Analytics & tracking providers such as: Google Tag Manager Google Analytics WordPress & Others

to detect, prevent and investigate fraudulent applications for products to undertake investigations into allegations of misconduct and/or criminal offences

Compliance with a legal obligation. We also consider that we have a legitimate interest in protecting ourselves, other parties and the financial services industry more widely in detecting, preventing and investigating financial crime and/or misconduct

The Financial Conduct Authority, National Crime Agency (NCA), Police, HMRC & Our partner organisations.

to notify the relevant authorities of any suspicious activity following an investigation undertaken by us into allegations of misconduct and/or criminal offences

to undertake anti-money laundering, identification and verification checks, including assessment of your sanction check information (any personal data obtained for the purposes of meeting with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 will only be processed for the purposes of preventing money laundering or terrorist financing, unless the use of the data is permitted by or under another enactment other than those Regulations, or we have another lawful basis for processing it)

Compliance with a legal obligation

External supplier(s) to conduct anti-money laundering, identification and verification checks on our behalf Our partner organisations.

to evidence satisfaction of any request made by you in accordance with your rights under data protection regulation

Compliance with a legal obligation

Information Commissioner’s Office

Special category data

Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.

We may process:

Health information and lifestyle information when providing quotes and services in relation to a protection insurance product.

In addition to the lawful basis for processing this information set out in the above table, we will be processing it either (i) for the purpose of arranging or administering an insurance contract or (ii) for the establishment, exercise or defence of legal claims.

Marketing

We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent and then will do so in accordance with any marketing preferences you have provided to us.

In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.

You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences, please contact us:

By email: dataprotection@Llamarewards.co.uk

By post: Llama Life Ltd 20 Canon Street, Taunton, TA1 1DP

Information provided on another person

If you are submitting personal information about another person, then you confirm that you have their consent to provide such information and for their information to be used as set out in this notice, and that you have provided a copy of this notice to that other person.

Information we share

Information about you is an important part of our business. We do not sell your information to any third parties. Llama Life and/or its agents or subcontractors only shares your information as described below. All information sharing is based on the principle of sharing only the information necessary to fulfil the legitimate business purpose. When shared, data may be transferred and hosted outside the European Economic Area.

Aggregated information from which no individual person could be identified representing the general use of the website is shared with your organisation to evaluate the effectiveness and value of the website;

Payment card information may be shared with payment processors to facilitate card transactions and identify transactions;

Bank account information may be shared with our bank to facilitate payment into your account;

Information may be shared with participating merchants in order to fulfil transactions, including payment information, shipping address and other personal information that may be required to complete the transaction;

All of the information we collect, as described above, to companies that perform traditional IT services on our behalf such as credit card processors, data management firms, call centre providers.

When we might share information with third parties

We may disclose your personal information to third parties in a very limited number of circumstances:

Sharing of personal medical data

Where we engage the business services of a third party to provide services directly to Llama Life and/or its agents or subcontractors. For example, we may use a mailing house to email promotional materials such as our email newsletter. Rest assured that any third parties are strictly prohibited from using your personal data for any other purposes.

In the event that we sell any business or assets, in which case we may disclose your personal data to the buyer of such business or assets.

If Llama Life and/or its agents or subcontractors or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use on this website and other agreements; or to protect the rights, property, or safety of If Llama Life and/or its agents or subcontractors, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

When analytics and search engine providers assist us in the improvement and optimisation of our website.

How we protect the information

We are committed to protecting the confidentiality of your information. We take reasonable measures to secure your information, this includes industry standard administrative, physical and technical controls. These controls include encryption, third party audits, access controls and security testing.

Data retention

We will hold your personal data for differing periods of time depending upon the reason we have for processing it. These retention periods are set out below.

Type of RecordRetention PeriodCustomer file containing a record of any services provided by usFor a period of six years following provision of services, or following termination of the policy.Complaint file containing a record of any claim you have brought against usFor as long as we reasonably consider that you might legally bring an additional or repeat claim against us, or for as long as we reasonably consider that the information may be requested by the financial regulator or ombudsman.Marketing listsOnce consent for marketing is received, we will use your data for marketing purposes until you opt out. We will then retain your data for a period of 6 months following the cessation of marketing activities.Results of anti-money laundering, identification and verification checks, including assessment ofFor as long as we are required/permitted to retain this personal data based upon our legal and regulatory obligationsyour sanction check information
Fraud and financial crime filesFor as long as we reasonably consider that:
we are required/ permitted to retain this personal data based upon our legal and regulatory obligations
they may be required in the establishment, exercise or defence of legal claimsRecords of satisfaction of any request made by you in accordance with your rights under data protection regulation3 years from the date the request was satisfied

Cookies

We may use cookies to provide you with the best experience whilst using the Rewards Website, to manage your browser sessions and to ensure the website’s optimal functionality. Cookies are required to allow you to use all of the website’s functions. Disabling cookies will limit functionality and may significantly hinder the user experience.

Some business partners (e.g., advertisers, tracking utilities) use cookies and web beacons on their site(s). Llama Life and/or its agents or subcontractors does not have access or control over these tracking technologies. Llama Life and/or its agents or subcontractors does not share your personal data with these advertisers.

This privacy and cookie policy covers the use of cookies on this website. It does not cover the use of cookies by any third parties.

For more information about cookies, including further details as to what they are and how to refuse them, please visit www.allaboutcookies.org.

Direct marketing

For you to successfully make use of this website, we may need to send you system generated emails. Other marketing type emails may contain an opt-out facility.

Opting-out

You may opt out of correspondence relating to the use of this website by using the Contact Us facility on this website.

If you would like your personal information, including email address, to be completely removed from our database, you should use the Contact Us to let us know. We will respond to your request within 14 business days. Completely removing your personal information from the database will negate your ability to login and use to the Llama Life Rewards Package.

Subject Access Requests

You are entitled to request a copy of your personal information held by us, as well as a description of how the information is used. A Subject Access Request should be made in writing to Llama Life or/its agents or subcontractors where appropriate

Third Party and Retailer’s privacy and cookie policies

Links on this website may redirect you to a third party or participating retailer’s web site. At the point you enter the third party web site, the privacy and cookie policy of the third party will apply to any information you provide. It is important to read and familiarise yourself with the third party‘s privacy and cookie policy.

Llama Life and/or its agents or subcontractors  reserves the right to disclose your personally identifiable information, as required by law and when it is believed that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process.

  1. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us using the contact details in section 1.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us using the contact details in section 1.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties
Internal third parties

Other companies related to the Inchora Group, of which Albany Park Limited is a member, acting as joint controllers or processors and who are based in the UK and provide IT and system administration services, Accounting Services, Compliance, Marketing and Communication Services and undertake leadership reporting.

Companies within the Swiss Re Group.

Companies within the Xexec Group

External Third Parties

  • Service providers acting as processors based in the United Kingdom who provide:
  • IT and system administration services
  • Credit reference agencies
  • Approved and appointed service providers, including those used to administer policies
  • Feedback and service references.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Notification of changes to this policy

Our privacy and cookie policy will be reviewed and enhanced from time to time. Please check our website or contact us for a copy of the current privacy and cookie policy. In this way you will be made aware of policy changes prior to carrying out further activity on this website. As always, if you are not amenable to the conditions of a revised privacy and cookie policy you may opt-out by means outlined earlier in the ‘Opting-out’ section above.