LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA
Yu life processes your personal data under a legitimate interest basis for the purpose of fulfilling your insurance contract. In relation to any of your health data outside of the fulfilment of your insurance contract we will ask for your explicit consent. We also operate on the basis of fulfilment of contract for any rewards not related to your health information.
WHAT INFORMATION DO WE COLLECT FROM YOU?
Information we collect may include: your name, address, email address and phone number, the device’s phone number, age, username, password and other registration information, financial and credit card information, personal description, photograph, health and wellbeing data. We have categorised the information we collect from you under the following headings:
- Insurance Information: information you submit to generate an insurance policy, health details, beneficiary details, information submitted during a claims process as required to generate and fulfil your insurance policy.
- Correspondence Information: information collected when you correspond with us via email, phone or chat, or when you report any problems with an app, our services, or any of our services sites.
- Usage Information: information you provide when you register to use the App or any services site, download or register an App, or subscribe to any of our services.
- Other engagement Information about your in-App purchases, or rewards redemptions. information about competitions you have entered, promotions you have engaged with, surveys you have taken, content relating to yu life that you have shared through the app’s social media functions. Device Information: the type of mobile device you use, unique device identifiers, mobile network information, your mobile operating system, the type of mobile browser you use, time zone settings.
- Locally stored Information: information stored on your device, for example: contact information, friends list, login information, photos or other digital content. You will be notified and asked to authorise our use of this data.
- Log Information: Error logs, details of your use of any of yu life’s Apps or your visits to any of yu life’s sites including, but not limited to traffic data, other communication data, error data and interactions with our rewards service.
- Wellness Information: information we access and store through integrations and connectivity through our app with Google Fit Services and/or Apple Health kit. You will be notified and asked for consent before connections are made.
- Location information: we may also use location-based services to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by accessing the app settings menu and turning off the location access features.
- Third-Party Information: on occasion, we work with third-parties (for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, fitconnect data aggregation services). We will notify you when we receive information about you from any other third-party and the purposes for which we intend to use that information.
WHY DO WE COLLECT THIS INFORMATION?
This section explains why we collect certain information from you and shows how we use the different types of information we collect.
There are three core reasons we collect such information:
- To assess your eligibility and enable us to offer insurance products that are tailored to you.
- To customise your in-app experience.
- To enable you to receive the benefits of our rewards program and achieve lower monthly subscription fees in the future
To help you understand what this practically means, we describe below how we use the different categories of information we described in the section above:
- Submitted Information: we use the personal data you submit, such as your name, address, and health information, in order to calculate the amount of cover we can offer you (this is determined through an automated process) and to determine your eligibility for our insurance products as well as to assess beneficiary details and to process claims
- Device Information: to understand what kind of platform you are using, where you are using it, and how we can best optimise your experience.
- Location information: to help monitor engagement and offer location-based challenges and activities.
- Content Information: we collect this information to track your progression and engagement with the app, to enable us to create better, more engaging challenges and rewards and help us create a more personal experience. To show at an aggregate level how users are engaging with the app.
- Log information: To improve monitoring and troubleshooting and analyse trends that help us administer our services. To track movement in an aggregated form and to gather broad demographic information.
- Third-Party Information: to better understand how we can improve our products and ensure the experience we create is optimised for our target audiences; and to create a more personalised experience for the end user.
- Wellness information: to analyse your holistic wellbeing and offer additional rewards, or potentially lower prices on insurance, to encourage you to engage with healthy activities, and to create large anonymised sample sets of data for research to better understand how a populous can improve their overall health by engaging with our product.
- Geo-location information: to more accurately assess your wellness goals to present more relevant, location-based rewards.
We may combine any category of information with any other category of information, and will treat the combined information as personal data, in accordance with this policy for as long as it is combined.
We may additionally use any of the above categories of information to perform automated decision making for product eligibility, customisation of the app, and rewards, as numbered above.
WHO MIGHT WE SHARE YOUR INFORMATION WITH?
We will disclose certain data we collect from you to the following third parties, including:
RGA: the insurance benefits included with your yu life membership are reinsured by the Reinsurance Group of America. In order for these insurance benefits to be administered it is required that your personal data is processed by RGA.
AIG Life Limited: the insurance benefits included with your yu life membership are underwritten by American Insurance Group. In order for these insurance benefits to be administered it is required that your personal data is stored by AIG. AIG also require policy details to administer any claims. You can find the full AIG privacy notice here: (https://www.aiglife.co.uk/privacy-policy)
PTL Governance Limited: If your membership has been bought for you by your employer it will have been put in trust with PTL. PTL will require your name, email, home address and payment details to fulfil any claims whilst the insurance benefit is in trust.
Third Party Suppliers: We may work with other business partners, suppliers, and subcontractors, for the performance of any contract we enter into with them or you:
- Third-party marketing companies: such companies require data to select and serve relevant adverts to you and others. We do not disclose any personally identifiable information to our advertisers, but we will provide them with anonymised, aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1), and to display targeted adds to this effect.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies: It may be necessary to assessing your credit score where this is a condition of us entering into a contract with you.
We will disclose your personal information to third-parties in the following circumstances:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If YU LIFE LTD 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 or regulatory obligation or request.
- In order to:
- enforce or apply any other agreement between Yu Life LTD. and our customers.
- protect the rights, property or safety of yu life, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
HOW DO WE KEEP YOUR DATA SECURE?
We make sure the data we collect from you will be transferred to and stored in regions that are deemed adequate by the European Commission. We will only allow people to process your data that fall under our list of approved processors. We will take all reasonable steps to ensure that your data is treated securely in accordance with latest best practice.
We will only store your information on our own secure servers or with approved third-parties who adhere to our security standards. For payments we use secure payment gateways such as Stripe and GoCardless to ensure that all your payment details held under the highest security standards.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our sites, you are responsible for keeping that password confidential. We ask you not to share your passwords with anyone.
We use certain services include social networking, chat room, or forum features. Please ensure when using these features that you do not submit any personal data that you do not want to be seen, collected, or used, by other users.
Unfortunately, the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites.
HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?
In order to insure you and maintain your rewards, we are required to keep your personal data for the duration of your policy.
Once you have cancelled your policy, we are required by law to keep your basic personal data (name, address, contact details) for a minimum of six years. We are also required by law to keep details of the insurance you were provided with beyond the cancellation of your policy.
If you do not use the app and other digital products for a period of 12 months, we will remove your personal data from our systems.
We will contact you to check if you still want to hear from us after the conclusion of your policy.
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data), if we intend to use your data for such purposes, or if we intend to disclose your information to any third party for such purposes and will ask for your consent to do so.
You have the right to ask us for access to any of the personal data we hold on you. If you would like to submit a Subject Access Request, please email firstname.lastname@example.org or use one of our in-app chat functions in the first instance.
You have the right to ask for a review of any automated decision making. To initiate a review process, please email email@example.com or use one of our in-app chat functions in the first instance.
If at any point you believe the information we process on you is inaccurate you can request to see this information, and submit a request to have this data corrected, and in some instances to have it deleted. You also have the right to withdraw your consent for processing data related to health. If you wish to raise a complaint on how we have handled your personal data or would like to initiate your right to any of the above, you can contact our Data Protection Officer (DPO) by emailing firstname.lastname@example.org. We will investigate your complaint and respond as a priority.
If you are not satisfied with our response, or believe we are processing your personal data not in accordance with the law, you can lodge a complaint with the Information Commissioner’s Office (ICO). Yu life are registered as a Data Controller with the ICO under the registration number: ZA312163
Our sites or apps may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the app or the services are advertised). If you follow a link to any of these websites, please note that these websites, have their own privacy policies, and that we do not accept any responsibility or liability for these policies, or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
CHANGES TO THIS NOTICE:
Any changes we may make to our privacy notice in the future will be posted on our website and, where appropriate, notified to you when you next start the app, or log onto one of our sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the app or the services.