Aviva Pension Skill – Privacy Policy

Please read this Privacy Policy carefully before using the Aviva Pension Skill.

The Aviva pension skill (“Skill”) is provided to you by Aviva UK Digital Limited (“Aviva”, “us” or “we”). The Skill enables you to receive information about your pension and other products you have with Aviva through the Alexa service made available by Amazon Digital Services LLC and/or its affiliates (“Amazon”). We are committed to protecting and respecting your privacy. This privacy policy (“Privacy Policy”) together with our Terms and Conditions (“Terms”) apply to your use of the Skill and sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal information and how it will be treated. For information related to other products and services you have with Aviva please refer to our general privacy policy which is published on our website here.

The Skill is not intended for use by children and we do not knowingly collect information relating to children.

  1. Communications through the Skill
  2. Information we will collect from you and how we use it
  3. MyAviva
  4. Purposes of processing your personal information
  5. Cookies and similar technologies
  6. Where we store your personal information
  7. Security and passwords
  8. Disclosing your information
  9. Third party sites and services
  10. Cancelling your account
  11. Your rights and access to information
  12. Contact us

1. Communications through the Skill

The Skill allows you to verbally request information from us through your Alexa-enabled device to obtain information about your pension and other products you have with Aviva by linking to your MyAviva account.

Any communication to and from us through your Alexa-enabled device will be treated as communication which you have requested and/or authorised. In order for this functionality to work, the information you request will be obtained directly by Amazon. Amazon is data controller in relation to this information. For more information on how Amazon handle your personal data for the purpose of performance of your contract with Amazon and your use of the Alexa Skill, please refer to their privacy policy which can be found here.

You are responsible for all interactions with us through the Skill, and you accept the risk that someone other than you may interact with us via your Alexa-enabled device or someone could over hear your interaction with us through your Alexa-enabled device and learn information about you.

2. Information we will collect from you and how we use it

We will collect and process the following information about you:

  • Customer data such as your policy ID, email address and name; and
  • Data items relating to your pension or other Aviva product such as pension valuation, contributions, your product renewal date, premium and date of last pension valuation.

We need this information to verify your identity and to provide the functionality to use the skill to meet contractual obligations; and

  • Your voice pin, chosen by you to access the Skill. We need this to ensure appropriate safeguards are put in place to protect your security. This information will not be made available to anyone else.

Without this information, we are unable to allow Amazon to access this data from your MyAviva account and provide the Skill functionality.

3. MyAviva

In order to make use of the Skill, if you don’t already have one, you will need to complete the registration process to register for a MyAviva account.

For information on MyAviva please see the terms and conditions and privacy policy made available on the MyAviva portal. The MyAviva portal also allows you to update your marketing and communication preferences.

Device information

We will collect information about the device you use to access the Aviva webpages made available through the Alexa service on the Amazon website or in the Alexa mobile application (“Aviva Webpages”), including, where available, the device's unique device identifiers, operating system, mobile network information, for system administration and statistical purposes, and to improve the performance of the Skill. This information will be automatically combined with the Submitted and Additional Information referred to in the sections above for customer services and system administration purposes. We will treat the combined information as personal information in accordance with this Privacy Policy for as long as it is combined. The information collected in this way will be used for web analytics purposes only, for example to identify where users are abandoning their journey so that we can make improvements and fixes for future versions.

Log Information and Aggregated Data

When you use the Skill (including the Aviva Webpages), we will also automatically collect and store certain information in our server logs to get a better understanding of how people use the Skill, for system administration purposes and to ensure we provide a good user experience and customer service.

Aggregated data

We also collect, use and share anonymous aggregated data such as statistical or demographic data.. Anonymous aggregated data may be derived from your personal information but will not directly or indirectly reveal your identity. For example, we may aggregate your Log Information to calculate the percentage of users accessing the Skill at a particular time. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat this combined data as personal information which will be used in accordance with this privacy policy.

This type of information includes information about when and how you use the Skill as well as date or time stamps. This information is used for service level reporting for example, so that we can identify when there may be high levels of usage.

Security and Fraud Prevention

Your personal information is used to ensure the security of your use of the Skill, your user account and our business, as well as for the purposes of preventing or detecting fraud or abuses of our services.

4. Purposes of processing your personal information

We process your personal information in order to operate, maintain and provide you with the features and various functionalities of the Skill (including the Aviva Webpages) as well as to provide customer service and support. We will always indicate where the provision of certain information is voluntary and you will be able to withdraw your consent or exercise your rights in relation to this information at any time as described under paragraph 11 of this Privacy Policy.

This means that the legal basis for us processing your personal information as described above will typically be one of the following:

  • because it is necessary to fulfil a contract that we have in place with you or a contract which you’ve entered into;
  • for our legitimate business interests such as the development of improved products and services;
    or
  • where the processing is necessary for compliance with our legal obligations.

5. Cookies and similar technologies

We use cookies and technologies which are similar to cookies in the Aviva webpages including MyAviva but not on the Alexa Skill. For general information on how Aviva uses cookies, please refer to the relevant webpage or site.

6. Where we store your personal information

We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. We apply criteria to determine the appropriate retention period for different categories of personal information you provide us with. For example, we will keep information necessary to protect us in a legal claim, such as information relating to a contract, for the lifetime of your product contract and up to seven years after. After this period it will be deleted or in some cases anonymised. Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. If we have anonymised your personal information or aggregated your personal information in a way that you can no longer be identified from it, then we will continue to keep and use this anonymised information. No additional data is stored by Aviva in order to deliver the Skill functionality.

7. Security and passwords

You must keep your password, your voice pin and any other authentication information confidential. You must not disclose it to anyone else. If you know or suspect that anyone other than you knows your password or any other authentication information, you must promptly notify us using the contact details below.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted via the Skill and/or Aviva webpages; any transmission is at your own risk.

8. Disclosing your information

We will disclose your personal information to:

(a) any member of our group of companies (a list of which can be found here www.aviva.com), which means our subsidiaries, our ultimate holding company and its subsidiaries; and

(b) suppliers, such as cloud hosting providers who provide services to us or on our behalf so you can use the Skill.

We may need to disclose your personal information: (a) to enforce any part of the terms and other agreements or to investigate potential breaches.

With your permission, we will use your personal details to promote the Skill. You will be contacted before any release of such information for our promotional purposes, and you may withdraw any permission that you may grant at any time.

9. Third party sites and services

In addition to Amazon’s privacy policy as referred to above, your use of the Alexa mobile application will also be subject to any app store provider and/or operator from whom you have downloaded the Alexa mobile application (“App Store Policies”). It is your responsibility to read and comply with the App Store Policies.

10. Cancelling your account

You can cancel your user account for the Skill at any time through your Alexa service. If you do so, we will delete any personal information we hold about you specifically in relation to the Skill apart from any information which is held in our back-up systems and information we hold which is anonymous. Back-up data is deleted periodically.

11. Your rights and access to information

Data protection legislation in the European Union and the UK gives you certain rights in relation to your personal information. These include:

  • the right to withdraw consent to the processing of your personal information;
  • the right to access to your personal information;
  • the right to request access to your personal information;
  • correct any mistakes on our records;
  • erase or restrict your personal information where they are no longer needed for the purpose for which they were obtained or used;
  • object to our use of personal information based on legitimate business interests, including for profiling and marketing; and
  • receive a machine-readable copy of, your personal information.

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. We will handle any request to exercise your rights in accordance with applicable law. If you wish to exercise any of these rights please refer to the “Contact Us” section of this Privacy Policy.

12. Contact us

If you have any questions about how we use personal information, or if you want to exercise your rights stated above, please contact our Data Protection team by either emailing them at alexa@aviva.com or writing to the Data Protection Officer, Level 4, Pitheavlis, Perth PH2 0NH.

If you have a complaint or concern about how we use your personal information, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have the right to lodge a complaint with the Information Commissioners Office at any time.

For the purposes of data protection legislation the data controller in respect of your personal information is: Aviva UK Digital Limited

This Privacy Policy was last updated in May 2018.

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