Background
Today, more information is being uploaded and shared across the web. For you to be confident using our services we want you to trust that not only are we providing you with the best deal, we’re also committed to ensuring your privacy is protected.
When we ask you to provide certain information, or obtain certain information by which you can be identified, rest assured that your information will only be used in accordance with this privacy policy.
We may change this privacy policy from time to time by updating this page. Where we make significant changes to it, for instance by adding a new reason for processing your personal data, we will also notify you of those changes via the email address that we hold for you.
Who are ManyPets?
We are your data controller for the purposes of the personal data we will collect. Our details are as follows:
ManyPets Ltd, a limited company registered in England with the company registration number 07886430 and registered address at Unit 1b Summers Street, London, England, EC1R 5BD.
If you wish to contact us in relation to this notice, or data protection, please contact our Data Protection Officer by email at dpo@manypets.com or by post using the address above, marked for the attention of the Data Protection Officer.
How do we process your data?
This privacy policy applies to all customers of ManyPets Ltd and VetBox Ltd (a company in the same group as ManyPets Ltd.) This privacy policy also applies to opted-in members of our email mailing lists, users of the ManyPets app when downloaded from the Apple Store or Google Play Store and users of these websites, whether logged-in or not logged-in to a user account:
manypets.com/uk (boughtbymany.com prior to 30/03/2022)
vetbox.com
plans.manypets.com
We will collect and process your personal data under some, if not all, of the following lawful bases: contractual necessity, our legitimate interests, consent, because it is necessary for us to comply with a legal obligation, the personal data has been manifestly made public and where the processing is necessary for reasons of substantial public interest.
Contractual necessity
Contractual necessity is where we collect your personal data because it is necessary for us to provide you with a quote, a contract of insurance, process insurance claims or to administer your ManyPets Health Plan or Vetbox subscription. Without this data, we would not be able to respond to your request or fulfil our contractual obligations to you.
We need personal data for the following reasons, to provide our service to you:
To arrange and administer insurance on your behalf. This will include several types of correspondence either via our website including live chat, or by post, email, a messaging service or phone call, for example: communications about a quote and purchasing a policy, your welcome pack and policy documents, claims status notifications, payment reminders, arrears notifications, confirmation of your cancellation, renewal documents, complaint communications, any changes you may request to your policy or personal details, and any communications in response to a query you have sent us.
To deliver, or to arrange for another party to do so on our behalf, products you have purchased from us as part of your plan or subscription, to your preferred address.
Legitimate interests
Organisations can rely on “legitimate interests” to process personal data where: (a) their reason for processing personal data is a legitimate business interest (b) the processing is a proportionate way of achieving that interest; and (c) that legitimate business interest is not outweighed by the impact on the individual. We have completed that assessment and are satisfied with it for each of the purposes set out below.
You do have a choice as to whether you provide us with your personal information and you have the right to object to us using your data for our legitimate interests. However, if you decline to provide us with certain personal information this may impact the services that we can offer to you.
We have a legitimate interest in each of the following:
Sending you marketing communications via email, post, messaging services, app notification or telephone calls for similar goods and services related to pet health or pet care where you have provided your details to us when you applied for or purchased one of our products or services. We will give you the opportunity to opt out of these communications at the outset and will include an unsubscribe in our emails. If you opt out or unsubscribe, we will not send you any more marketing communications but please note that it will take our systems time to update and process the change. Opting out of receiving marketing communications or unsubscribing from them will not stop you getting communications or messages about your account, plans, subscription, products, and services that you have purchased since we will still need to contact you to administer these. Promotional emails about products or groups we think you may be interested in. Customising our website or app according to your interests (e.g. we might give pet insurance products more prominence on the page because you have told us you have a dog).
Customising the marketing material we send you (e.g. we send newsletters containing relevant articles based on your activity on our website or app).
Displaying pet health or pet care related messages or advertising to you on third party social media, search engines, messaging platforms or content-driven websites, such as but not limited to Google, Facebook, Whatsapp and Tiktok, where permitted by your agreement with and use of those third party services, to (a) show you messages or adverts based on your characteristics or interests, e.g. to only show our advert to people interested in dogs; or (b) show you messages or adverts based content you have viewed on our websites or apps, e.g. where you have read an article about specialist pet insurance, we might show you an advert for one of our specialist pet insurance products; or (c) show you messages or adverts based on the plans, subscriptions, products and services you have purchased from us, or those for which you have previously viewed a price or requested a quote.
Obtaining financial reports from insurers detailing purchases by ManyPets Ltd customers and website or app users on third-party insurer websites.
Improving our products, services, benefits, or incentives with online surveys and by emailing you asking you to complete a survey, either provided by ourselves or by a partner organisation such as but not limited to Feefo, Trustpilot, Google and Medallia, to enable you to leave reviews of how you found the experience of dealing with ManyPets Ltd.
Monitoring website and app usage, including usage statistics and third-party hyperlink click tracking. We use Google analytics to do this and we do not have access to the underlying data, only aggregated views of it (e.g., to see how many users visited our website in a certain timeframe, which pages were most popular, and which website visitors came from for instance directly, via Google, or from Facebook).
Tracking if you have purchased a product from a cash-back site, through a link on a partner website or via another affiliate to enable us to pay the correct third-party.
Creating Management Information to help us with pricing decisions.
Bringing a legal claim or defend legal claims against us.
Using your comments on specific social media posts to inform the development of new insurance products, refinement of our marketing strategy or improvement of our service.
We may use your telephone number to call you or message you to see if we can help you with purchasing a pet insurance policy.
Consent
Where we rely on consent, we will only process your personal data in that way if you have told us we can. Usually this will be by ticking a box or agreeing over the phone. You have the right to withdraw consent at any time.
We typically rely on consent to:
Send you marketing communications not related to products, services, plans and subscriptions which you have bought from us, or for you have requested a price or quotation, where you have not explicitly requested it from within our websites or apps, or by clicking a link in one of our emails.
Sharing your details with a 3rd party so that they may send you marketing communications, where you have not explicitly requested it from within our websites or apps, or by clicking a link in one of our emails.
Legal obligation
This is where we are required by a law or regulation to process your data to fulfil our legal obligations.
We process your personal data to comply with our legal obligations where:
We are required by our regulator to analyse customer feedback on the product to enable us to make product improvements.
We are required to complete a sanctions check prior to selling insurance to a customer. A sanctions check is a search of an individual against government sanction databases that identify people who are prohibited from entering the financial services environment, including buying insurance products.
We are required to confirm whether you have received and/or opened policy-related emails (e.g., your policy documents when you purchase a policy from us).
Manifestly made public
Where you post a comment on our Facebook page, Google profile, Instagram posts, Feefo page or Trustpilot page, for instance where we have asked for thoughts on pet ownership, pet health issues or your experience of our products, plans, subscriptions or services, we may use that comment to inform the development of new insurance or pet health products, or republish it, alongside your name and location where stated, as part of our marketing communications.
Public Interest
Where we need to process special categories of data (e.g., data relating to your health) to arrange or administer your insurance policy, we do so because it is necessary for reasons of substantial public interest (as set out in UK data protection law).
What personal data do we collect?
To enable us to process your data, we collect the following personal data:
Contractual
Personal information such as name, title, date of birth, email address, postal address, telephone number.
Details of your insurance needs and interests.
Information you submit when obtaining a quote or purchasing an insurance policy including declarations (e.g. have you ever been declined insurance).
User and password information, as well as device information and IP address taken during account set up, or login process for our app or website
Policy adjustments made during the policy term, claims made during your policy term.
Your bank details, credit, or debit card information.
Information shared with us during a telephone call, which will be recorded.
Information shared with us during a chat session, or on email.
Current and historical policies held, and your policy renewal dates.
Legitimate Interests
Your membership of programmes, clubs, or customer loyalty scheme we create and serviced through our website, apps, or email campaigns.
Personal information such as name, date of birth, email address, postal address, telephone number, to be able to provide you with customer or member benefits, such as marketing emails, messages, or app notifications.
If Facebook login credentials were used to register on the ManyPets website (boughtbymany.com prior to 30/03/2022), your Facebook profile. We will also have access to your Facebook ‘likes’, Facebook friends who are customers of or users of websites belonging to ManyPets Ltd, and email address if you give us permission to access this data during the registration process.
Your social media IDs and handles where they are linked to your account if you used social media credentials to register with our website or app.
What products you have previously viewed or shown interest in.
We also collect website and app usage data, including: your IP address, the browser you used to access our website, the website from which you came, the device used, the pages you visit and functions you use, and the hyperlinks to other websites which you click on.
Legal obligation
Personal information such as name, date of birth, email address, postal address, telephone number.
Manifestly made public
We obtain personal data from comments you have posted on our Facebook posts and Instagram posts, as well as reviews you have posted on sites such as Feefo, Trustpilot and Google where you choose to publish your name and location.
Where do we obtain your personal data from?
We obtain your personal data in the following ways:
From you via web forms, your use of our app or during telephone calls, for instance when signing up for an account, joining a programme, club or customer loyalty scheme or expressing an interest in a policy, plan, subscription or other product or service we offer.
Automatic recording, for instance interests based on the groups you join, the articles you read (and how long you spend reading them), the buttons you press to obtain a quote or share an offer, your location through your IP address, your internet service provider and the type of device or browser you are browsing with.
From the social media accounts you connect to your Bought By Many/ManyPets account. Note: the personal data from social media accounts that we have access to is determined by the permissions you give us when registering with our website or app.
From you where you have disclosed this data to us through an online survey, by leaving comments on one of our discussion forums or Facebook pages, or by sending us a direct communication containing this data (e.g., email or direct message).
From online veterinarian pharmacies when you buy medication and then submit this cost as part of your claim.
From other relevant companies that supply preventative medicines or treatments
How do we share your personal data?
In general, access to your personal data will be restricted to those who have a need to access it to carry out their duties (for example our employees such as our customer service team).
However, we will also share your personal data with the following external third parties in some circumstances:
Fraud prevention agencies or other third parties that assist us in preventing fraud or other forms of risk (anti-money laundering agencies and credit agencies).
Regulators such as the Financial Conduct Authority (FCA), and government authorities such as Her Majesties Revenue Commission (HMRC) or the police, if we are required to do so by law or if the regulator or authority requests it and we regard that request as reasonable.
Our insurers, legal advisers or other third parties who need access to it in the context of managing, investigating, or defending claims or complaints.
Potential buyers of all or part of our business and/or their advisors.
Organisations that process your data on our behalf who are not allowed to use your data for any other purpose, for instance our web hosts and third-party email broadcast tools.
Other companies within our group, for instance where they provide us services.
Referral scheme providers, including but not limited to Mention Me (mention-me.com), if you take up our referral rewards offer. Your details will not be used for anything other than to help you refer your friends and manage your rewards.
Our nominated vet consultation service as detailed within your policy document. We will give them your name, your pets name, email address, policy number, mobile telephone number and date of birth. We will also share clinical histories and vet visit information.
If you purchased your policy via Pets Corner UK Ltd, we will pass your name and email address to them via SFTP. We do this so that Pets Corner UK Ltd can send you the insurance purchase incentive advertised in their stores. You can find out more on how Pets Corner UK Ltd will use and store your data in their privacy policy which can be found here https://www.petscorner.co.uk/privacy-policy.
If you are introduced to us via another company such as a price comparison website. We will inform them that you completed the purchase of your policy on our website or app. We will securely send them your name and email address. To find out how they process and store your data, please go to their websites to view their privacy policies.
Companies who provide marketing support services to us, such as direct mail marketing. We may share your personal data with reputable third-party service providers in connection with automated marketing services provided by such third parties to us.
Your vet practice, we will give them your name, your pet's name, email address, policy number, mobile telephone number date of birth, policy details and claim history to allow them to process a claim on your behalf.
We aim to share only anonymised data or aggregated data wherever possible. We will use secure means to store and share data. We also require third parties to sign legally binding agreements not to use any information for marketing purposes and not to share this data. This may not be possible in all circumstances, for instance where we are obliged to disclose data to a regulator.
Do we make solely automated decisions?
We use an automated insurance rating engine to evaluate insurance risk based on the information you supply us during the quote process. We use this information to automatically determine your potential risk, and whether we are able to offer you a quote and, if we are able to offer you a quote, what the value of the quote will be.
We also make solely automated decisions based on personal data to screen you against government sanctions databases prior to allowing you to buy a contract of insurance - we are required to do this by law. Whilst this automated decision could result in us not offering you a contract if insurance, this would only be automated where the system determines a 100% match. Most of the time there is not a 100% match, and one of our staff will therefore review the decision manually.
We may use an automated process to validate and evaluate all or part of your insurance claim to us, and to handle payment where a claim has been approved. Use of an automated process for your claim does not affect your right to appeal a decision.
You have the right to contest any decision produced by a solely automated means and request for human intervention. If you do this, we must allow you to express your point of view, to obtain an explanation of how we reached the decision and allow you to challenge the decision. To do this, please contact our Data Protection Officer by calling our customer services department on 0345 340 4090 or you can email our Data Protection Officer at dpo@manypets.com
Do we transfer your data outside of the EEA?
We store your personal data in cloud servers based in the European Economic Area (EEA) and we may also store your personal data on servers based in the US. In certain circumstances, we will also use processing services based within the US.
We only transfer your personal information outside the EEA where we have a legal basis for doing so and where we require that your personal information is protected to the same standard as it would be protected in the EEA. We do this by entering into data-sharing agreements with the recipients of your personal information based outside the EEA which comply with the European Union’s Standard Contractual Clauses (SCC) for the transfer of personal information.
If you would like further details about our transfer of your personal information outside the EEA or details of the safeguards put in place in relation to your personal information please contact our Data Protection Officer by email at dpo@manypets.com.
How long we keep your information for?
If you are a customer, we will keep your personal information and all telephone conversations for a period of 6 years after you cancel your policy. We need to keep your information for this amount of time as required by law (including FCA regulations) or in order to defend potential legal claims.
Your bank and card details will be deleted at the point that you cancel your policy.
Email communication that we have had with you will be deleted 6 months after you cancel your policy.
As a user of a website or app belonging to ManyPets Ltd or Vetbox Ltd that has never bought a policy through us, we will keep your personal information until either:
you cancel your membership of a programme, club, or customer loyalty scheme
you request that your user account is closed
you have not responded to the email we send asking whether you wish your account to remain active (we typically send this one month before your account is due to be deleted).
Where you provide us feedback about your experiences during the course of our research and it has not already been anonymised, we will either (a) delete your personal data from our systems; or (b) anonymise it, at the end of that project.
How can you opt-out of or unsubscribe from receiving marketing communications?
If you do not wish to receive further marketing information about our products and services, you can contact us by calling our customer services department on 0345 340 4090 or you can email our Data Protection Officer at, dpo@manypets.com. You can manage your marketing preferences within the “My Account” section of our website or app and we will also include unsubscribe links within all our marketing emails.
How do you withdraw your consent for us to process your personal data?
You have the right to withdraw your consent to how we process your data in circumstances where we are using your data based on consent. To withdraw your consent, you can do this by calling our customer services department on 0345 340 4090 or you can email our Data Protection Officer at dpo@manypets.com
How can you object to us processing your personal data based on our legitimate interests?
Where we process your personal data based on our legitimate interests for direct marketing purposes, you always have the right to object to that processing. To object to direct marketing either follow the instructions for opting out of marketing in the section above, or contact our Data Protection Officer by calling our customer services department on 0345 340 4090 or you can email our Data Protection Officer at dpo@manypets.com
You have the right to object to other processing based on our legitimate interests, but we might not have to cease processing where you do so if either:
We can demonstrate legitimate grounds for the processing which override your interests; or
Where that legitimate interest is the establishment, exercise, or defence of legal claims.
To object to legitimate interests processing, please contact our Data Protection Officer by calling our customer services department on 0345 340 4090 or you can email our Data Protection Officer at dpo@manypets.com
What are your rights concerning your personal data?
You have the right to obtain your personal data from us except in limited circumstances. The first copy will be free of charge, but we reserve the right to charge a small fee for additional requests if they are disproportionate.
You have the right to require us to rectify any inaccurate personal data we hold concerning you.
Considering the purposes of the processing, you may also have the right to have incomplete personal data completed, by means of providing a supplementary statement or otherwise.
You have the right to require us to erase your personal data on certain limited grounds (including where they are no longer necessary for the purpose for which they were collected or where we rely on consent, which you withdraw, and there is no other legal ground for the processing).
Where we process personal data, either on the basis of consent or contractual necessity, that you provided to us, and we process that personal data by automated means, you have the right to require us to give you your data in a commonly used electronic format.
You have the right to object to our processing of personal data which we process on the grounds of our legitimate interests, as detailed in the paragraph titled “ objecting to our legitimate interest processing” above.
You have the right to require us to restrict the processing of your personal data on certain grounds, including where: you contest the accuracy of the personal data and want us to restrict processing of your personal data while we verify its accuracy; the processing is unlawful, but you request a restriction of the processing rather than erasure; we (as controller) no longer need the data for the purposes of the processing, but you have told us you require us to retain that personal data for you to establish, exercise or defend legal claims; or you have objected to us processing your personal data on grounds of legitimate interests and want us to restrict processing of your personal data while we consider your objection.
If you would like to exercise any of these rights, please contact our Data Protection Officer by calling our customer services department on 0345 340 4090 or you can email our Data Protection Officer at dpo@manypets.com
How can you make a complaint?
If we can’t remedy an issue you have, or you remain unhappy with how we are handling your data, you can lodge a complaint with the Information Commissioner’s Office (ico.org.uk).
How do we use cookies?
A cookie is a small file of letters and numbers that we store on your browser or your electronic device. We use cookies to improve and personalise your online experience, and to analyse our website and ad performance. We use first-party and third-party cookies. Some cookies are set directly by us; some others are placed by third party services to help us identify which other websites may have directed you to our website. This is so we can personalise our marketing to you and understand our website usage. For example, we use Google Analytics, to collect standard information and improve our website usage but this information is processed in a way which does not identify any individual. To manage your cookie preferences for manypets.com/uk or for plans.manypets.com click on ‘Manage cookies’ at the bottom of the page. To learn more about how we use cookies read our Cookie policy.
What happens when you click a link to another website?
Our websites and apps contain links to third party websites, including those of both insurance and non-insurance companies we partner with.
Once you use these links to leave our website or app, you should note that we do not have any control over those other websites. We, therefore, cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and sites not governed by this Privacy Policy. You should exercise caution and look at each website’s own privacy policy.
What other data do we collect?
We collect a range of other non-personal data from you which is not covered under GDPR. This is used by us either in fulfilment or our contractual obligations to you, or to assist with our marketing, product development or providing you with discretionary benefits or services.
We may also combine this data with your personal data during processing, to do these things, as described above This other data includes but is not restricted to:
Details of your pet’s species, breed, age, gender and health history whether provided during the insurance process, plan set-up or account set up for our app or website.
Details of the vets or online pharmacies you use.
Data you have voluntarily shared with us, through surveys or in the setting up of your account in our app or website, such as habits, routines or general pet ownership needs not related to insurance.