Aviva Investors is committed to protecting your personal information. The privacy and security of your personal information is very important to us. We want to assure you that your information will be properly managed and protected whilst in our hands.
- any Aviva Investors website that links to this Policy (“Websites”); and
- social media or Aviva Investors content on other websites.
It also relates to our use of any personal information we collect through other means, such as email, in person or other third party sources.
For information concerning any other companies in the wider Aviva Group, please visit www.aviva.com.
*Aviva Investors Group of Companies:
Aviva Investors Holdings Limited
Registered in England, No. 2045601. Registered Office: St Helen’s, 1 Undershaft, London EC3P 3DQ.
Aviva Investors Global Services Limited
Registered in England, No. 1151805. Registered Office: St Helen’s, 1 Undershaft, London EC3P 3DQ. Authorised and regulated by the Financial Conduct Authority. Firm Reference Number 119178.
Aviva Investors Pensions Limited
Registered in England, No. 1059606. Registered Office: St Helen’s, 1 Undershaft, London EC3P 3DQ. Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Firm Reference Number 110410. Member of the Association of British Insurers.
Aviva Investors UK Fund Services Limited
Registered in England No.1973412. Registered Office: St Helen’s, 1 Undershaft, London EC3P 3DQ. An Aviva company. Authorised and regulated by the Financial Conduct Authority. Firm Reference Number 119310.
Friends Life Funds Limited
Registered in England No.7304839. Registered Office: St Helen’s, 1 Undershaft, London EC3P 3DQ. An Aviva company. Authorised and regulated by the Financial Conduct Authority. Firm Reference Number 629488.
The information we collect and how we collect it
Personal data will be processed by Aviva Investors for the purposes of sales, administration and marketing.
We may receive personal information about you, when you contact Aviva Investors for example by doing any of the following:
- purchasing an Aviva Investors product from us or from one of our partners
- using the Websites
- entering Aviva Investors competitions; and
- telephoning, or writing by post or email
This information may include:
- personal identification and contact details such as your name, address, e-mail address, telephone number, date of birth and National Insurance Number / Tax Reference number;
- your marketing preferences
- sensitive personal information. We will always be clear to explain when and why we need this information and the purposes for which we will use it.
Personal information about others
If you give us information about another person it is your responsibility to ensure and confirm that:
Information collected from your use of our Websites
We collect information through “Cookies” and other similar technologies (e.g. pixel tags or links), to remember you when you visit the Websites and so we can improve your online experience to suit your needs. These help us understand how you and others use our Websites, view our products and respond to our advertising, so we can tailor marketing and enhance our overall product and service offering. This also saves you from re-inputting information when you return to the Websites.
When you receive marketing from us via email, we may use technology e.g. pixel tags or links to determine your use of and interest in our marketing.
When you visit one of our Websites we may record your device information including hardware and software used, general location, when and how you interact with our Websites and your registration and log-in activity when you use our online platforms. This information is retained and used to note your interest in our Websites and improve customer use experience.
We may use and share information from or with online sources, such as websites, social media and information sharing platforms. This information may be used to help tailor and improve our services and communicate with you effectively, as we know many of our customers use a range of media channels.
Where we use or share information from or with these sources, we will respect any permissions you have set about how you would like your information to be used.
We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms.
How we use information to improve our products and customer experience
We may use your information for research, statistical and training purposes, including to analyse how people use our Websites, view our products, respond to our advertising and to improve our understanding of what customers need.
Telephone calls may be recorded for training and monitoring purposes, and to comply with applicable law and regulations.
How we use and share your information within the Aviva Group
We may share and aggregate information about you across the Aviva Group, including personal information held within the Aviva Group relating to other products held with us or other companies within the wider Aviva Group. Depending on your preferences, we may use this information to:
- help us identify products and services that may be of interest to you, to tailor and package our products and services;
- conduct customer research and develop marketing campaigns; and
- for the prevention or detection of crime (including fraud).
How we share your information outside of the Aviva Group
We may disclose your information to third party suppliers or service providers to conduct our business, for example, to help administer your product, to help us manage and store data, provide data analytics, conduct market research and to communicate with you effectively. This may include any online or digital partners we work with, so we, or our online or digital partners on our behalf, can communicate with you through their platforms.
In addition, unless you opt out of receiving direct marketing, we may share your information with third parties who help run our marketing campaigns.
Your information may also be disclosed when we believe in good faith that the disclosure is:
- required by law;
- to protect the safety of our employees, the public or Aviva Investors property;
- required to comply with a judicial proceeding, court order or legal process;
- in the event of a merger, asset sale, or other related transaction; or
- for the prevention or detection of crime (including fraud).
Fraud Prevention and Detection
We may, as a matter of law, and without requiring notice or consent, obtain information about you from our third party suppliers and other third party databases to detect and prevent fraudulent activity within the Aviva Investors Group and to monitor and/or enforce Aviva Investors' compliance with any regulatory rules and codes. We may also share your information with regulatory bodies in the UK or if applicable, overseas, as well as with other companies (directly or via shared databases) to prevent and detect fraud.
Fraud Prevention and Detection
In order to prevent and detect fraud we may at any time:
- share information about you with other organisations and public bodies including the Police;
- undertake credit searches and additional fraud searches;
- check and/or file your details with fraud prevention agencies and databases, and if you give us false or inaccurate information and we suspect fraud, we will record this to prevent fraud and money laundering.
We can supply on request further details of the agencies and databases we access or contribute to and how this information may be used. If you require further details contact us at: Policy Investigation Unit, Aviva, Cruan Business Centre, Westerhill Business Park, 123 Westerhill Road, Bishopbriggs, Glasgow G64 2QR. Telephone 0345 300 0597. Email: PIUUKDI@aviva.com.
We and other organisations may also search these agencies and databases to:
- help make decisions about the provision and administration of credit and related services;
- trace debtors or beneficiaries, recover debt, prevent fraud and to manage your accounts;
- check your identity to prevent money laundering, unless you furnish us with other satisfactory proof of identity;
- check details of job applicants and employees.
Data transfer and consent
Your information may be transferred by any Aviva Investors Group company to any country, including countries outside of the European Economic Area (EEA), for processing, storage, administration or any other use stated in this policy. The purposes and processing associated with any such transfer will comply with all applicable data protection regulations, including the UK Data Protection Act, and with our obligation to adequately protect and secure your personal information. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in the EEA.
By providing your personal information to Aviva Investors you consent to the transfer of your information as described above.
We are committed to protecting the confidentiality and security of the information that you provide to us and we put in place appropriate technical, physical and organisational security measures to protect against any unauthorised access or damage to, or disclosure or loss of, your information.
You should also be aware that communications over the internet, such as e-mails, are not secure unless they have been encrypted. The Websites may contain links to websites of the wider Aviva Group and other third party websites. You should carefully read the privacy policies of these websites before submitting any personal information.
Managing your marketing preferences
We, other members of the Aviva Group and our and their agents may use your information to keep you informed by post, telephone, e-mail or other means of products and services that may be of interest to you.
We will always give you the opportunity to ‘opt out’ when you receive any email, text or other direct marketing communication. You can also opt out of the use of your information for these purposes by writing to us at:
Aviva Investors, Freepost, Mailing Exclusions Team, Unit 5, Wanlip Road Ind Est, Syston, Leicester, LE7 1PD
Update your information
Please let us know if your information changes as it is important that the information we hold about you is accurate and up to date.
You can ask us to update or correct your personal information by writing to us at the address below.
How to find out what information we hold about you
You have the right to request a copy of the personal information we hold about you in a Subject Access Request. To do this, simply write to us at the address below.
We will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you.
How to contact us
The Data Protection Office, Aviva Investors (Floor 10), St Helen's, 1 Undershaft, London. EC3P 3DQ.