We care about your personal data
We appreciate your interest in our products and services and your visit to this website. Your privacy is important to us and we want you to feel comfortable with how we use and share your personal information.
1. Who is the data controller?
A data controller is the individual or legal person who controls the use of the data and is responsible for keeping it safe. The laws apply to personal data in both paper and electronic files. AWP Assistance UK Ltd and Mercedes-Benz Cars UK LTD trading as smart are joint data controllers as defined by relevant data protection laws and regulations.
AWP Assistance UK Ltd, trading as smart Warranty Services (“we, “us” “our”), a subsidiary company of Allianz Partners SAS, is authorised and regulated by the Financial Conduct Authority in the United Kingdom to provide insurance products and services. Protecting your privacy is a top priority for us. This notice explains how and what type of personal data will be collected, why it is collected and with whom it is shared. Please read this notice carefully.
2. What personal data will be collected?
Depending on the type of insurance product or service we provide to you, we will collect and process various types of personal data about you:
- surname, first name
- place of residence
- date of birth
- telephone numbers
- email address
- credit/debit card and bank account details
- CCTV images (we may collect this if you visit one of our offices).
some of which may be required for fraud detection purposes
Warranty and Roadside Assistance
In the event of a claim under our warranty and roadside assistance products where a hire car is provided, we will collect and process data relating to driving related convictions which may affect our ability to provide a hire car to you.
Travel and Homecare
We may also collect and process special category data about you, such as medical information, where you have purchased a travel or homecare product from us.
3. How will we obtain and use your personal data?
We will collect and use the personal data that you provide to us and that we receive about you (as explained below) for a number of purposes. We provide more information in the following table:
|Purpose||Do we need your express consent?|
|the administration of products (for example, sending details of cover, handling claims, providing quotes, underwriting)||no|
|to administer debt recoveries||no|
|fraud prevention and detection||no|
|to meet any legal obligations (for example, regulatory, tax, accounting and administrative obligations)||no|
|to redistribute risk by means of reinsurance and co-insurance||no|
|to enhance, modify, personalise or otherwise improve our services/ communications for the benefit of our customers||no|
|to enhance the security of our networks and information systems||no|
|to better understand how people interact with our websites||no|
|to determine the effectiveness of promotional campaigns and advertising||no|
From time to time we may wish to inform you, or permit Allianz Group companies and selected third parties to inform you about products and services that we feel may be of interest to you in accordance with your marketing preferences. However, we can only do this with your express, written consent. You can change your mind about this at any time by contacting us as set out in section 10 below.
We will process personal data we receive about you from third parties such as brokers and business partners, other insurers and fraud prevention agencies.
We will process your personal data where it is necessary for us to comply with our contractual obligations to you, or where we need to take pre-contractual steps at your request.
We will process your personal data where necessary for the purposes of our legitimate interests. “Legitimate interests” means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. For example, we may process your information to invite you to renew your policy upon expiry or protect you against fraud when transacting on our website and to ensure that our websites and systems are secure. When we process your personal information for our legitimate interests, we make sure that we consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests –we will not use your personal data where our interests are overridden by the impact on you (unless we are required or permitted by law).
Special category data is personal data which is regarded as more sensitive and so needs greater protection, such as medical records. In the event of a medical emergency or claims under our travel and homecare products, we may need to share this information with selected third parties such as doctors and hospitals. In such circumstances, where necessary to protect your health, we will process and share such data either with your explicit consent or, where this is not possible, we will do so in order to protect your vital interests.
We will need your personal data and use it for the purposes described above if you would like to buy our products and services. If you do not wish to provide this to us, we may not be able to provide the products and services to you.
CCTV cameras are in operation at our offices for health and safety, prevention of crime and prevention of damage to our building and company assets. We may collect video recordings and still pictures which feature you, if you are in the field of vision of any of our CCTV system. These images are only held for a period of ninety days.
4. Who will have access to your personal data?
We will ensure that your personal data is processed in a manner that is compatible with the purposes indicated above.
For the reasons stated above, your personal data may be disclosed to the following parties who operate as third party data controllers depending on the type of policy you have bought from us:
- other Allianz Group companies; experts such as technical consultants, lawyers and loss adjustors; repairers, taxi companies and car hire companies in the event of a claim under our warranty or roadside assistance products; ticket sellers under our event cancellation products; homecare providers under our homecare products; engineers to provide boiler breakdown and repair services under our home emergency products; third party repairers in respect of our appliance protection products; service companies to discharge operations (claims, IT, postal, document management); and
- the manufacturer of your vehicle and their franchised dealers, authorised repairers and vehicle recovery operators;
- doctors and other health professionals in the event of a medical emergency; airline companies in the event of repatriation.
- For the reasons stated above, we may also share your personal data with the following who act as data processors under our instruction:
- other Allianz Group companies, technical consultants, experts, lawyers, loss adjustors, repairers, vehicle recovery operators in the event of a vehicle breakdown and service companies to discharge operations (claims, IT, postal, document management); and
- advertisers and advertising networks to send you marketing communications, as permitted under local law and in accordance with your communication preferences. We do not share your personal data with non-affiliated third parties for marketing purposes without your permission.
Finally, we may share your personal data in the following instances:
- in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in any insolvency or similar proceedings); and
- to meet any legal obligation, including to the Financial Ombudsman Services if you make a complaint about the product or service we have provided to you.
5. Where will my personal data be processed?
Your personal data may be processed both inside and outside of the European Economic Area (EEA) by the parties specified in section 4 above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose your personal data to parties who are not authorised to receive it.
Whenever we transfer your personal data for processing outside of the EEA by another Allianz Group company, we will do so on the basis of Allianz’s approved binding corporate rules known as the Allianz Privacy Standard (Allianz’s BCRs) which set out our commitment to maintain the same high level of protection for personal information regardless of where it is processed. The BCR’s are legally binding on all Allianz Group companies. Where Allianz’s BCRs do not apply, we will instead take steps to ensure that the transfer of your personal data outside of the EEA receives the same level of protection as it does in the EEA. If you would like more information on the BCRs, please see section 10 below.
6. What are your rights in respect of your personal data?
Where permitted by applicable law or regulation, you have the right to:
- access the personal data held about you and to learn the origin of the data, the purposes and ends of the processing, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed;
- withdraw your consent at any time where your personal data is processed with your consent;
- update or correct your personal data so that it is always accurate;
- delete your personal data from our records if it is no longer needed for the purposes indicated above;
- restrict the processing of your personal data in certain circumstances, for example where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy;
- obtain your personal data in an electronic format for you or for your new insurer; and
- file a complaint with us and/or the Information Commissioner’s Office.
You may exercise these rights by contacting us as detailed in section 10 below.
7. How can you object to the processing of your personal data?
You have the right to object to us processing your personal data, or tell us to stop processing it (including for purposes of direct marketing). Once you have informed us of this request, we shall no longer process your personal data unless permitted by applicable laws and regulations.
You may exercise this right in the same manner as for your other rights indicated in section 6 above.
8. How long do we keep your personal data?
We will retain your personal data for a maximum of seven years from the date the insurance relationship ends. If we are able to do so we will delete or anonymise certain areas of your personal data as soon as that information is no longer required for the purposes for which it was obtained.
9. Automated decision making, including profiling
We may use automated decision making, including profiling, to assess insurance risks, detect fraud, and administer your policy. This helps us to decide whether to offer the insurance and determine prices.
If you have any concerns regarding the decision reached, please let us know at the contact details set out in section 10 below and we will arrange for a person to check the accuracy of the result.
10. How can you contact us?
If you have any queries about how we use your personal data, you can contact us as follows:
By post: Data Protection Officer, AWP Assistance UK Ltd, 102 George Street, Croydon, Surrey CR9 6HD
By telephone: 0208 603 9853
By email: AzPUKDP@allianz.com
We will need details of your name, email address, policy number, and purpose of your request.
11. How often do we update this privacy notice?
We regularly review this privacy notice. This privacy notice was last updated in April 2019.