Effective Date: 3 May 2018
Our Privacy Principles
When we collect and use your Personal Content, we ensure that we look after it properly and use it in accordance with our privacy principles set out below, keep it safe and will never sell it.
- Personal Content that you provide is processed fairly, lawfully and in a transparent manner.
- Personal Content that you provide is collected for a specific purpose and is not processed in a way which is incompatible with the purpose which Trōv collected it.
- Your Personal Content is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
- Your Personal Content is kept accurate and, where necessary kept up to date.
- Your Personal Content is kept no longer than is necessary for the purposes for which the personal information is processed.
- We will take appropriate steps to keep your Personal Content secure.
- Your Personal Content is processed in accordance with your rights.
- We will only transfer your Personal Content to another country or an international organisation outside the European Economic Area where we have taken the required steps to ensure that your Personal Content is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect it to adequate standards.
- Trōv does not sell your Personal Content and we also do not permit the selling of customer data by any companies who provide a service to us.
How, what and why do we collect your Personal Content?
There are are number of ways in which we collect your Personal Content, the two main ways we might collect Personal Content about you are from things you tell us yourself, and from things we ask other people or organizations to share with us. Below is an explanation relating to how, what and why we collect Personal Content.
We collect and process the following data about you:
- Information that you give us
- This is information that we collect, for example, when you register with us, download the Trōv Service, use the Trōv Service, submit application or quote forms, fill in forms via the Trōv Service, feedback forms, surveys or vote in polls, correspond with us (for example, by email or post), report a problem with the Trōv Service, cookies, telephone calls, submit a claim via the Trōv Service or make a purchase;
- Information we collect about you and your device
- We automatically collect certain technical information about you when you use the Trōv Service including your device identifier and location, how you use the Trōv Service, language selection and preferences;
- Information we receive with appropriate permissions, from third parties
- We collect information about you from third parties, such as insurance companies with whom we partner, business partners, analytics providers, credit reference agencies and any social media sites that you may use, such as Facebook, Twitter, YouTube and LinkedIn. The information supplied to us by such third parties is regulated by their respective privacy and cookies policies; and
- Cookies and other similar technologies
- We collect cookies and other similar identifiers to distinguish you from other users of the Trōv Service. For detailed information about the cookies we use and the purposes for which we use them, please see our Cookies Policy.
Further details of the Personal Content we collect and why we collect it is set out below.
If you register a Trōv Account:
We May Collect
Why We Collect It
Your email address
The language selected and geographic area of your device when you use the Trōv Service
Your device identifier
Your location information, if you elect to share it
Actions you perform, including your use of certain product features, as well as the type of device and software you are using
Anonymous logging of our HTTP API usage
Information regarding items that you add to your Trōv Account
If you purchase Protection with Trōv:
We May Collect
Why We Collect It
Full name, email, phone number (if provided), home address, age (D.O.B.), country of residence, nationality, location information
Information about the protected item(s) in your Trōv account including photographs that you upload and the related metadata.
Details related to Trōv Protection transactions, financial information such as bank details, claims & other communications (email, chat, phone)
Please note that Trōv Protection cannot be purchased unless you provide the above data.
If you visit trov.com:
We May Collect
Why We Collect It
Your email address, full name, phone number, age, postcode, gender (if you provide it)
IP address, pages visited, browser type and settings, cookies and similar tracking information
View our Cookies Policy for more details.
Communications, transactions and experiences between you and Trōv
To better assist you and other users with the Trōv Service.
We must have a legal basis to use your personal information. In most cases the legal basis will be one of the following:
(a) to fulfil our contractual obligations to you, for example to ensure that we provide you with the Protection you have purchase;
(b) to comply with our legal obligations, for example our obligations to a third party (e.g. taxation or financial services authorities); and
(c) to meet our legitimate interests, for example to ensure that the services we provide are appropriate to your needs, that we protect ourselves from fraudulent activities, that we can deal with any complaints or concerns that you raise.
You’re in control of how we use your Personal Content for marketing purposes.We will only contact you if you’ve agreed it’s okay. Then, we might use your Personal Content and your marketing preferences to build a profile about you and to inform you of our products and services which we consider may be of interest to you.
We may share information within the Trōv-family of companies to inform you of other products and services that may be of interest to you or members of your family, but we will only do this where you have provided your consent. You can always change your mind by contacting us using details shown in your documentation and telling us you no longer wish to be contacted.
We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to unsubscribe from marketing emails sent by us, you may do so at any time by following the unsubscribe link found in the footer of all of the emails sent to you. However, if you purchase Trov Protection, you will continue to receive legally required service-related and account-related information and documents (all non-marketing), even if you unsubscribe from marketing emails. You may opt out of any app notifications from Trōv through the settings in the Trōv Service on your device (iOS or Android). Otherwise you can always contact us using the details set out in your documentation to update your contact preferences.
From time to time we may run specific marketing campaigns through social media and digital advertising that you may see which are based on general demographics and interests. Individual personal information is not used for these campaigns. If you do not want to see any campaigns then you will need to adjust your preferences within social media settings and your cookie browser settings.
Please note that we may retain any data provided to us on our website or app for a limited period, even if you do not complete your quote. The information may be used to inquire as to why you did not complete your quote or for us to better understand your needs, but only if you have agreed for us to contact you.
Does Trōv Share My Personal Content?
We may share your Personal Content with businesses that are legally part of the same group of companies that Trōv is part of, or that become part of that group ("Affiliates"), or that are contractors to Trōv or its Affiliates that are contracted to provide services on behalf of Trōv or its Affiliates. All these businesses are subject to confidentiality requirements. Affiliates and contractors may use this information to help provide, understand, and improve the Trōv Service. These Affiliates and contractors will honor the choices you make about who can use your data.
Partners, such as distributors, channel partners and other third parties with whom Trōv jointly offers products or services (where requested by you) to fulfill product or information requests, and/or to provide customers or prospective customers with information about Trōv and its products or services.
On rare occasions, we may be required by law, legal process, litigation, or governmental authorities, including to meet national security or law enforcement or regulatory requirements to disclose your Personal Content. In such instances, if permitted by law, we will notify you of such request, and allow you to object to the disclosure of such information.
Trōv may also disclose Personal Content in special cases when we have a good faith belief that such action is necessary to protect and defend our legal rights or property, enforce website terms and conditions, or to protect the interests of our users or others.
We may disclose your Personal Content in connection with the sale, bankruptcy, dissolution, reorganization or other business transition such as merger, acquisition, or sale of all or part of Trōv’s business, as permitted by applicable law. When permitted we will inform you of such disclosure prior to the implementation of any of these changes, and will provide you with an opportunity to remove your personal data from the Trōv Service.
While we do not share Personal Content without your separate permission, we may publicly share aggregated, non-identifiable data, for example, anonymized reports related to categories of items owned in different geographies or other aggregate insights related to the things that people own and are protecting, for marketing and business development purposes.
If You Choose to Purchase Trōv Protection
We partner with leading insurance companies to provide Trōv Protection for items in your Trōv. If you do not purchase Trōv Protection through Trōv, then none of your Personal Content is shared with our insurance partners. If you choose to purchase Trōv Protection for an item or items in your Trōv, then your Personal Content is shared with the issuer of the product. This is required in order to effectively deliver the Trōv Protection service.
Payment Service Providers
Disclosure to other Third Parties
App Analytics & Communication
Preventing & Detecting Fraud
To help keep premiums low by detecting and preventing fraud and other crimes, we may, at any time, disclose information about you to:
- Other organizations and public bodies including the police;
- Our underwriting partners and other insurers;
- Recognized insurance industry application, policy and claims checking systems;
- Insurance fraud registers - this may affect future applications for insurance products;
- Check details and any information with fraud prevention agencies and databases, including publicly available data - if false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies to prevent fraud and/or money laundering;
- At inception of the relationship and periodically thereafter provide information to and obtain information from fraud prevention agencies, services, and credit reference agencies in order to (i) help make decisions on insurance policies and claims for you or your financial associates; (ii) trace people who owe money, recover debt, prevent fraud and to manage your insurance policies and the insurance services that we provide; (iii) check your identity to prevent money laundering and to comply with “Know Your Customer” or similar obligations; or (iv) carry out credit searches and further fraud searches. Please note that any personal content provided to or obtained from a report of credit reference agencies may be retained by the credit reference agencies and disclosed to other persons.
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 email@example.com.
Data Storage, Transfer and Deletion
How do I Make Changes to My Personal Content?
You may make changes to your Personal Content by logging into the Trōv mobile application and editing your Personal Content.
Where Is My Personal Content Stored?
How Secure Is My Personal Content?
We take appropriate precautions to protect your Personal Content through technology, policy and procedures. For example, we use industry standard (SSL) encryption to protect your network communications; to the extent allowed by law, we run background checks on our employees; and we architect our networks to protect access to our storage servers. In addition to maintaining our high level of security, we are always striving to increase our security measures.
You are an important part of securing the data in your Trōv Account. We recommend you use a strong password for the Trōv Service. You should use the security features of your devices, including passcodes, Touch ID, and lost device location services. We are not responsible for any unwanted access to your Trōv Account due to your poor security of your devices or personal password.
How do I delete Personal Content in my Trōv?
You can delete the items in your Trōv at any time and they will be removed from our servers, if you have never purchased Trōv Protection for them. You cannot delete items that have been subject to Trōv Protection, because we are required by law to retain these records. Residual copies of your deleted Personal Content, regardless of whether you’ve purchased Trōv Protection, may remain on our backup systems for several months due to the nature of those systems' operations.
If you'd like to stop all communications related to your account, you can deactivate it through the settings menu in the Trōv application. Note, deactivating your account will not delete the items in it; this needs to be done manually prior to deactivation. Please note, however, that if you obtain Trov Protection even if you deactivate your account, we must maintain your account on our system and retain necessary records relating thereto. As a result, even if you deactivate your account, you will continue to receive legally required service-related and account-related information and documents. If you deactivate your account you can log in to your account at any time to re-activate it.
You have the following rights in relation to our use of your Personal Content.
Requesting Access to or Correction (rectification) of Personal Content
We take such steps as are reasonable to ensure that the Personal Content we collect and hold about you is accurate, up-to-date and complete. However, we rely on the accuracy of the Personal Content you provide to us. You may request a copy of the Personal Content which we hold about you and certain details of how we use it. If you believe that any information we are holding about you is incorrect or incomplete, please visit uk.trov.help.
Once we receive a request for access and/or correction of your Personal Content, we will respond to that request within a reasonable period after the request is made and in any event within the timescales required by law. There will not usually be a charge for dealing with these requests. Your Personal Content will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means.
We will promptly correct any information found to be incorrect. There are some exceptions, specified by law, where we may refuse your requests. If one of these circumstances applies, we will provide you with a written explanation of the reasons for the refusal, unless it would be unreasonable to do so.
Right to Erasure
In certain circumstances, you have the right to ask us to erase your Personal Content, for example, where the Personal Content that we collected is no longer necessary for the original purpose or where you have withdrawn previously provided consent. However, this will need to be balanced against other factors, for example, according to the type of Personal Content we hold about you and why we have collected it, there may be some legal and regulatory obligations which we cannot comply with your request.
Right to Restriction of Processing
In certain circumstances, you are entitled to ask us to stop using your Personal Content, for example, where you think that the Personal Content that we hold about you may be inaccurate or where you think that we no longer need to process your Personal Content.
Right to Data Portability
In certain circumstances, you have the right to ask that we transfer any Personal Content that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your Personal Content.
Right to Object to Direct Marketing
You can ask us to stop sending you marketing messages at any time. Please see the Marketing section above for more information.
Right Not to be Subject to Automated-Decision Making
Some of our decisions are made automatically by inputting your Personal Content into a system or computer and the decision is calculated using certain automatic processes rather than our employees making those decisions. We make automated decisions in the following situations:
- Making offers and recommendations - in order to select personalised offers, discounts or recommendations to send you based on your Product history.
- Deciding your premium - For example, we use Personal Content that you and others have provided to us about you such as postcode, claims history, how long you have been a customer, and how much you pay in premium to determine your premium and eligibility.
- Fraud prevention - We also make automated decisions about you based on your Personal Content in order to protect ourselves from fraud where we base our decisions on automated anti-fraud filters that check against lists of people known to have undertaken fraudulent transactions and will reject those applicants on the basis they are likely to defraud the company. We obtain this data from you and third parties such as credit reference agencies and Know Your Customer vendors. We need to profile you and make automated decisions in order to protect our business from fraudulent activity. This may mean we do not permit the purchase of a Product.
- Assess your application - We may use scoring methods to assess your application and to verify your identity. Examples of information used by our systems to do this include your age and your postcode.
Trōv uses individual credit information about you to provide to us by third parties in order to assess your suitability for insurance and the price we offer to you. The information used to assess your insurance risk includes, but is not limited to, the following: verification of your residence via bills or electoral rolls, historic payment behaviour on financial products, or prior insolvency. If we are unable to validate your residence at the insured address or if we consider your historic payment behaviour with creditors to be significantly adverse we will decline to offer you a price for your insurance risk.
You have a right not to be subject to automated decision-making in the circumstances described above and where automated-decision making is used in the assessment of your application or fraud prevention, you can contact us to request that any declined decision is reconsidered with human intervention. If you want to opt out of automated-decision making, let us know, although in some circumstances it may mean we can’t offer you a quote or protection as some automated decisions are necessary to provide your protection.
Right to Withdraw Consent
For certain uses of your Personal Content, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your Personal Content. Please note that in some cases we may not be able to process your protection if you withdraw your consent.
Right to Lodge Complaint, Inquire About or Invoke Any of Your Rights
If you have any concerns about our handling or treatment of your Personal Content, if you believe your privacy has been breached, or to inquire or invoke any of your rights, please contact firstname.lastname@example.org, setting out the nature of your complaint. We will investigate your complaint and provide you with our response within a reasonable time of receiving your complaint and in any event within the timescales required by law.
If after receiving our response, you still consider that your privacy complaint has not been resolved, you may refer your complaint to the Information Commissioner’s Office at www.ico.org.uk.
In compliance with the Privacy Shield Principles, Trōv commits to resolve complaints about our collection or use of your Personal Content. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Trōv at email@example.com.
Trōv has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
Children’s Privacy Protection
The Trōv Service is not directed to children, nor do we knowingly collect any personally identifiable information from children under 13 years of age through the Trōv Service or software. If we learn that we have collected personally identifiable information from children under 13 years of age, we will delete such information.
Choice and Means
If, at any time after you provide us with Personal Content, that information changes, you change your mind about receiving information from us, wish to cancel your account or request that Trōv no longer use your information to provide you services, or to otherwise inquire or involve any of the rights listed in the Your Rights section above, contact us via firstname.lastname@example.org. Additionally, you can delete the items in your Trōv at any time and they will be removed from our servers, if you have never purchased Trōv Protection for them. You cannot delete items that have been subject to Trōv Protection, because we are required by law to retain these records. Residual copies of your deleted Personal Content, regardless of whether you’ve purchased Trōv Protection, may remain on our backup systems for several months due to the nature of those systems’ operations. If you’d like to stop all communications related to your account, you can deactivate it through the settings menu in your Trōv. We will retain and use your information for as long as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
Investigatory and Enforcement Powers of the FTC
Trōv is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). Trōv also is committed to cooperating with EU DPAs.
If you are located in the EU and have exhausted all other means to resolve your concern regarding potential violations of Trōv’s obligations under the Privacy Shield Principles, you may seek resolution via binding arbitration. For additional information about the arbitration process please visit the Privacy Shield Website www.privacyshield.gov.
If a third party service provider providing services on Trōv’s behalf processes personal data from the EU in a manner which is inconsistent with the Privacy Shield Principles, Trōv will be liable unless we can prove that we are not responsible for the event giving rise to the damages.
Attn: Data Protection Officer
347 Hartz Avenue
Danville, California 94526
Trōv International UK Ltd
The Broadgate Tower, 3rd Floor
Attn: Data Protection Officer
20 Primrose Street
London EC2A 2RS