Privacy Policy

2. How we collect and use your personal information

1. We collect your full name and email address & your country of residence when you create an account in order to set up your account and security features;
2. We collect Information relating to your current life stage (e.g. whether you have children, and your work status), and the relationship to other people associated with you in our records (for example, partner, parent and child) and the gender you identify as. We also collect your date of birth within form questions in our application. Apart from basic mandatory information that we need to collect to set up and administer your account, it is up to you how much information you choose to share;
3. We collect identification information such as your date of birth, passport and driving licence details when you select services provided by our partners that require identity verification for the provision of health and wellbeing services to you;
4. We collect your location in the app with your consent, to direct you to relevant services based on location;
5. We collect appointments with, and orders for, third party services that you make when you book an appointment, order a service, health assessment or consultation with an external provider via our app. We do this to track your activities in relation to the goals you have set and to notify you of upcoming activities and appointments. ;
6. We collect your payment information such as payment amount, bank details and credit card details when you subscribe to our services and make a payment. We do this to collect payment for the services we provide you on the date we have stated. We do not retain any card payment data but transfer you directly to a secure payment processor to facilitate your payment;
7. We collect your contact details such as a telephone number and postal address as part of your account set up to send you information about other products and services that may interest you, where you have given your consent for us to do so. We also use this data to administer your account in the event that you have any account issues and need to call our Customer Service Centre. These details may be used to verify your identity on a customer service call. We may pass your details to a third party if you raise an issue related to a third party service;
8. When you access our mobile application, we collect information about how you navigate within the app, via Google Analytics and the feedback tool (Pendo). We use Google Analytics to improve the design and use of our application by understanding how users interact with different elements and the personalised services provided. We use Pendo to help direct what service messages to send to you;
9. When you access our website, we collect information from you through the use of cookies and similar technologies. Please refer to our Cookie Policy for further details;
10. For corporate customers, we collect employment details directly from your employer, such as the name of the employer and work location. We provide aggregated anonymised reports back to your employer on the level of use of our services but these reports cannot identify you;
11. We collect information about the goods and services you have with other AXA companies, to understand how AXA products are bought in combination with each other, to assist in the development of our products and improve our service delivery to our customers;
12. We collect your marketing preferences from you when you create an account to send you information on new products and services, offers and discounts;
13. Where we can, and it is appropriate, we will minimise personal information or de-personalise data to use for statistical or analytical purposes

4. More information about how we collect your personal information

We collect your personal information directly from you when you use our digital wellbeing service platforms. Before you create an account, we will collect anonymous information on users who download our mobile application. If you then create an account, we will initially collect your name and contact details to enable the creation of that account. 

Once your account has been created, we will collect further information from you in the following ways:

1. when you purchase or use any of our products or services;
2. when you vote in a poll on our website or interact with us on social media platforms;
3. via customer service telephone calls with you, which may be recorded. 

We may collect your personal information from a number of different sources including:

4. directly from an individual or employer (or your employer’s service provider) who has a policy with us under which you are insured, and in which a digital wellbeing service is provided to you as part of that policy;
5. directly from an employer which funds a Healthcare Trust that we administer where you are a beneficiary;
6. from credit reference agencies who will supply us with information, including information from the Electoral Register and credit information. Please note that the agencies may record details of the search whether or not your application proceeds;
7. from social media platforms, in particular when fraud is suspected; and
8. Other third parties including:
   1. partners who work with us to provide our digital wellbeing services directly to you;
   2. third parties such as companies who provide consumer classification and other personal information for marketing purposes e.g. market segmentation and lifestyle data; and
   3. third parties who provide information which may be used by AXA to inform its pricing and service modelling decisions.

6. Our legal basis for processing your personal information

1. When we need your personal information to provide you with an account on our digital platform our legal basis is that such use is necessary in order to provide you a service under contract. Our legal basis for processing your health data (which is Special Category Personal Data) is that you have confirmed your explicit consent (please note that, in some cases, if you do not provide your explicit consent we may not be able to provide a service). The type of data we may process for this purpose will include but is not limited to: your contact and identifying details and your country of residence as stipulated in Section 2.1, 2.3 and 2.7 above; and personal information about your physical or mental health or condition as stipulated in Section 3 above;
2. When we need your personal information to administer, provide and service your subscription our legal basis for processing is that such use is necessary in order to take steps to provide you a service under contract and our legal basis for processing your Special Category Personal Data is that you have provided your explicit consent. Please note that, in some cases, if you do not provide your explicit consent we may not be able to provide a service. The type of data we may process for this purpose will include, but is not limited to: your contact details and identifying details as stipulated in Section 2.1, 2.2, 2.3 and 2.7 above; information about your location as stipulated in Section 2.1 above; your healthcare provider(s) as stipulated in Section 3.4 above; your financial and payment details (such as payment card or bank account details) as stipulated in Section 2.6 above; and, Special Category Personal Data about your physical or mental health or condition as stipulated in Section 3 above;
3. When we need your personal information to develop our service proposition further, by monitoring the use of our digital platforms and services offered, our legal basis for processing is that we have a legitimate business interest to assess and improve our services to ensure we are continually improving and updating our products for the benefit of our users. In some instances, we will link your data from the navigation of our platform to your account authentication, in which case we will collect your consent for this processing. The type of data we may process for this purpose will include but is not limited to: your IP address or User ID number and information about the pages and objects you have visited within the app and links to any external sites as stipulated in Section 2.8 above;
4. When we need your personal information to communicate with you and resolve any issues or complaints you may have, our legal basis is that such use is necessary for our performance under our contract with you and we have a legitimate business need to resolve any issues or complaints. The type of data we may process for this purpose will include but is not limited to: your contact and identifying details as stipulated in Section 2.1, 2.3 and 2.7 above; your financial details and any information relevant to any payments you have made as stipulated in Section 2.6 above; and, Special Category Personal Data about your physical or mental health or condition as stipulated in section 3 above;
5. When we need your personal information to prevent, detect and investigate fraud (which may include technology related to voice analytics),  our legal basis is that such use is necessary in order to provide a service to you and we have a legitimate business need to prevent fraud. Our legal basis for processing Special Category Personal Data is that we need to use your personal data for reasons of substantial public interest to prevent and detect fraud. The type of data we may process for this purpose will include but is not limited to: your contact and identifying details as stipulated in Section 2.1, 2.3 and 2.7 above; employment details as stipulated in Section 2.9 above; your payment information as stipulated in Section 2.6 above; and Special Category Personal Data about your physical or mental health as stipulated in section 3 above;
   
   Additional Information about our use of this data: we may verify with fraud prevention agencies and databases including publicly available data (for example data related to County Court Judgements, bankruptcy information and electoral roll data) any details you have provided to us.  If false or inaccurate information is provided and if fraud is suspected, details will be passed to fraud prevention agencies that we work with to prevent fraud and money laundering and we will periodically search records held by fraud prevention and credit reference agencies to:  help make decisions about credit services for you and your financial associates; trace people who owe money, recover debt,  and to prevent fraud; check your identity to prevent money laundering; carry out credit searches, electoral roll searches and further fraud searches.   For more information about the agencies with which we share your data, including further details explaining how the information held by fraud prevention agencies may be used, please email us at fraud@axa.co.uk;
6. When we need your personal information to review or assist others such as the Care Quality Commission to assess the performance of healthcare providers to identify concerns regarding the care being provided to our customers and the public, our legal basis is that it is in the public interest to identify, or help others identify, deficiencies in the standards of care being provided. Our legal basis for processing Special Category Personal Data is that such use is necessary for reasons of public interest in the area of public health. The type of data we may process for this purpose will include but not limited to: contact and identifying information as stipulated in Section 2.1, 2.3 and 2.7 above; and, Special Category Personal Data about your physical or mental health or condition as stipulated in section 3;
7. When we need your personal information for our own management information purposes including; managing our business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice (e.g. tax or legal advice). We also undertake measures to secure our system and to ensure the effective operation of our systems. Our legal basis is that we have a legitimate business need to use your personal information to understand our business and monitor performance and maintain appropriate records, to protect the security of our systems. Our legal bases for processing Special Category Personal Data are that you have provided your consent. The type of data we may process for this purpose will include, but is not limited to: contact and identifying details as stipulated in Section 2.1, 2.3 and 2.7 above; payment information as stipulated in Section 2.6 above; Special Category Personal Data about your physical or mental health or condition as stipulated in Section 3 above; and, employment details as stipulated in Section 2.9 above.
   
   Additional Information about our use of this data: we use your personal information to help us understand our business and monitor our performance, for example, to help determine pricing of our subscription services. If you are a member of a large group health insurance or healthcare trust scheme, we may provide reports of aggregated data to your employer or a parent company on the performance of the scheme, the interactions with our digital platform and on the health of the workforce. The information we provide is anonymised so that you cannot be identified from the reports;
8. When we need your personal information for research, statistical analysis and product development purposes to improve our products and services, our legal basis is that we have a legitimate business need to use your personal information for services improvement.  Our legal basis for processing Special Category Personal Data is that you have given your consent. The type of data we may process for this purpose will include but is not limited to: contact and identifying details as stipulated in Section 2.1, 2.3 and 2.7 above; payment information as stipulated in Section 2.6 above; Special Category Personal Data about your physical or mental health or condition as stipulated in Section 3 above; and, employment details as stipulated in Section 2.9 above. 
   
   Additional information about our use of this data: We may use your personal information for research and statistical analysis including general research into health-related areas and research about the products and services we provide. Where possible, we will take steps to anonymise, pseudonymise, aggregate or place appropriate controls and governance in place to protect Special Category Personal Data. By analysing customer information, we can tailor and improve our products and services to better suit the needs of our customers. AXA accelerate its understanding through innovation such as machine learning and Artificial Intelligence. This means we work with new technology for efficiency and speed. When we do this we do so in accordance with data protection laws and regulations, and we consider each use on a case-by-case basis, ensuring that we have undertaken a full data protection risk assessment.  To have an accurate understanding of all AXA products you hold, we bring relevant personal information together across the AXA UK Group of companies.  Please note we only ever market to you if you have provided your consent;
9. When we need your personal information to provide improved quality, training and security (which may include technology related to voice analytics), for example, with respect to recorded or monitored phone calls to our contact numbers, we have several legal bases that may apply for us to process your data such as where we need to comply with our legal or regulatory obligations ( for example where this is necessary for proper performance with our contract with you). Our legal basis for processing Special Category Personal Data is that it is required for an Insurance purpose or you have provided your consent. The type of data we may process for this purpose will include, but is not limited to: contact and identifying details as stipulated in Section 2.1, 2.3 and 2.7 above;  your payment information as stipulated in Section 2.6 above; and  any additional information you might otherwise give us during your interactions with us;
10. When we need your personal information to provide information to you about our products and services as a personal customer or potential personal customer, our legal basis is either that this is in our legitimate business interest or we have your consent. Our legal basis for processing Special Category Personal Data is that you have provided your consent. The type of data we may process for this purpose will include but is not limited to: contact and identifying information as stipulated in Section 2.1, 2.3 and 2.7 above; lifestyle and information about social circumstances as detailed in Section 4 above; information about the goods and services you currently have with AXA as stipulated in Section 2.10 above;  and marketing preferences as stipulated in Section 2.11 above;
11. When we need your personal information to provide information to you about our products and services as a business customer or potential business customer (including information about other products), our legal basis for is that it is in our legitimate business interests for marketing within the commercial sector, or we have your consent. The type of data we may process for this purpose will include but is not limited to: your business contact information and publicly available information about your business.
12. When we link your personal and Special Category Personal Data across different products and services that you receive across the AXA Group to create aggregated data for the purposes of analytics and reporting. Our legal basis for processing is that we have a legitimate business need to use your personal information for analysis and reporting so that we can better understand how AXA products work together in order to benefit our product development and service delivery. Our legal basis is that you  have given your consent. The type of data we may process for this purpose will include but is not limited to: contact and identifying details as stipulated in Section 2.1, 2.3 and 2.7 above; payment information as stipulated in Section 2.6 above; Special Category Personal Data about your physical or mental health or condition as stipulated in Section 3 above; and, employment details as stipulated in Section 2.9 above.
13. When we need your personal information to provide a continuity of service with third party services that you select to use, we may transfer your personal information and Special Category Personal Data to third party service providers. Our legal basis for transferring your personal data is that you have provided your explicit consent. The type of data we may process for this purpose will include but is not limited to: your contact details and identifying details as stipulated in Section 2.1, 2.2, 2.3 and 2.7 above; information about your location as stipulated in Section 2.1 above; and Special Category Personal Data about your physical or mental health or condition as stipulated in Section 3 above.

8. How long do we keep records for?

In most cases, we will keep your information for between three and ten years after our relationship with you ends but it will vary depending on what data we hold, why we hold it and what we’re obliged to do by the regulator or the law.

We keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply or demonstrate compliance with our legal and regulatory obligations.  Where we can, and it is appropriate, we will minimise personal information or de-personalise data to use for statistical or analytical purposes.

The time period we retain your personal information for will differ depending on the nature of the personal information and what we do with it. We typically keep payment information for up to 7 years to comply with financial reporting requirements.  Beyond seven years we will keep minimised information for statistical analysis, for example for pricing and service delivery improvement purposes.

10. Marketing

You’re in control of whether we may use your information for marketing purposes.  If you are an existing customer, we will only contact you if you’ve agreed it’s okay. Then, we might use your information to tell you about products and services that could interest you. 

 We may use pixels and similar technologies within our marketing emails to enable us to see whether the email was delivered and accessed, and to provide us with insights into the performance of our campaigns so we can provide you with more relevant content at optimum times. 

If you wish to unsubscribe from emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in all emails. Otherwise you can amend your consents in the Privacy Centre on our digital app. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary. 

We would like to keep you informed, from time to time about relevant products and services. We may do this by mail, email, telephone or other electronic methods such as text message. In order to help us get to know you and identify what products and services may interest you we obtain information about you from other sources inside and outside the AXA Group for example, companies who provide consumer classification, market segmentation and lifestyle data for marketing purposes. Examples of these organisations are Experian or LexisNexis.

We may run specific marketing campaigns through social media and digital advertising that you may see which are based on general demographics and interests.  We do this by creating generic customer characteristics which are viewed in social media. If you do not want to see any campaigns then you will need to adjust your preferences within social media settings and your browser cookie settings. 

From time to time we may share your data with social media platform providers who aggregate elements of your personal information and match this data against other sources to find similar profile individuals. If you do not want us to use your personal information in this way, you can opt out of profiling at any time by visiting the Preference page in the app and opt out of ‘Help us to find new customers’

Business to business marketing (that is, commercial marketing) may rely on legitimate business interests when contacting the organisation rather than marketing choices made by an individual.