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 (where we hold an email address).
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.
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 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
What personal data do we collect and how do we use it?
Under data protection laws, we are required to explain what personal information we process about you, how we use this personal information and why. We are also required to have a "lawful basis" on which we process your personal data. We have summarised this for you in the below table:
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| Website and app visitors | To administer our website and app. To deliver material to our website and app and to measure or understand the effectiveness of our advertising and marketing. To monitor website and app usage, including usage statistics and third-party hyperlink click tracking. Tracking your online activity where 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. | "Technical data" such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. | Necessary in our legitimate interests of running our business, improving the website and our app for the benefit of you and other customers to whom we provide products and services; or We rely on your consent where the data is collected via a cookie, which requires consent. |
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| When you enquire or purchase one our products or services | To fulfil our agreement with you which may include: • To arrange and administer insurance on your behalf. This will include several types of correspondence either via our website or app 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, process your payment, 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. • process insurance claims or to administer you ManyPets Health Plan or Vetbox subscription. • 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. • to share your personal data with our partners in order to provide you with the partner benefits you have signed up to. • creating management information to help us with making underwriting and pricing decisions. Recording calls, you make to us for the purposes of staff training and business improvement. Obtaining financial reports from insurers detailing purchases by ManyPets Ltd customers and website or app users on third-party insurer websites, in order to pay third party commission. | Personal information such as name, title, date of birth, email address, postal address, telephone number. Details of your insurance needs. Information you submit when obtaining a quote or purchasing an insurance policy including declarations (e.g have you ever been declined insurance). Your bank details, credit or debit card information. Information shared with us during a telephone call. Information shared with us during a chat session, or on email. Current and historical policies held, and your policy renewal dates. Your membership of programmes, clubs or customer loyalty scheme including member benefits. Policy adjustments made during the policy term and claims made during your policy term. | Contractual necessity; To establish, exercise or defend our legal rights; or Necessary in our legitimate interests to improve our business and to train our staff. |
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| When you create a user account | To enable registration of your account and to administer and manage your account. To manage your membership of programmes, clubs, or customer loyalty scheme we create and services through our website, apps or email campaigns. | User and password information, as well as Technical Data, personal information provided as part of setting up your account, information about the products and services you have purchased from us, your benefits and our partners. | Necessary in our legitimate interests to provide our products and services to you, to communicate with you about key information directly and to remember you when you sign into your account; or Necessary to comply with our legal obligations when selling products and services to you. |
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| Through social media or third-party website pages such as Youtube, Google, Meta, LinkedIn, Tiktok,Feefo or Trust Pilot | When you send us a direct message so that we can respond to you. 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 or products. 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. | Name, email, information you display through your social media profile and the information you provide in your message, comment or post. What products you have previously viewed or shown interest in. Technical 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. | Necessary in our legitimate interests to respond to messages and to improve and promote our business; Where information has been manifestly made public; or We rely on your consent where the data is collected via a cookie which requires consent. |
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| Individuals we market to | To send you marketing communications about pet care, news, competitions, events, promotions, products and partner benefits. Sharing your details with our 3rd party partners, 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. 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. | Name, email address, phone number, contact address, preferences | With your consent (which shall include where the data is collected via a cookie which requires consent); or Necessary in our legitimate interests to send you marketing information (and you have not opted out). |
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| To understand our marketing and interactions with our customers and to provide personalised marketing to our customers | 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). 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 newsletter 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 Youtube, Google, Meta, LinkedIn 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. | Technical Data, name, email and social media profile details. | Necessary in our legitimate interest to understand how our customers interact with our marketing in order to personalise our marketing, improve our marketing and products and services that we offer; or We rely on your consent where the data is collected via a cookie which requires consent. |
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| To meet out legal duties and obligations | We may need to process your information to comply with a legal obligation or to defend, manage or process a legal claim. This may include: • where we are required by a regulator to analyse customer feedback on a product to enable us to make product improvements; • where we are required to complete 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; and • where 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). | Name, contact details, policy details, address, email, claims details | To comply with our legal obligations. |
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| When you complete an online survey or provide feedback | We may ask you by way of online surveys and by emailing 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 in order to improve our products, services, benefits or incentives. | Name, email, feedback details, purchase details | Necessary for our legitimate interests (to obtain feedback from our customers in respect of our products). |
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| When you enter a competition through our website, social media pages or app | To administer any competitions which you enter. | Social media contact, name, email and delivery address | Necessary for the performance of a contract with you when you enter into a competition; or Necessary in order to comply with our legal obligations when running a competition. |
| Processing activity | Why do we use your information? | What information is collected? | What is our lawful basis for processing |
|---|---|---|---|
| Notify you about changes | To notify you about important changes and developments to our website, app and our products and services | Name, email, address | Necessary in our legitimate interests (to update you about our products, our business, updates to any terms of service or otherwise communicate with you); or Necessary in order for us to comply with our legal duties. |
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:
Third party providers who provide additional services to you;
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, including but not limited to VetBox Limited.
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.
Our Partners
When you use our services, we offer additional services which include services from our third party partners.
Those third party partners are separate data controllers and how they process your personal data shall be subject to their separate privacy notice.
We will only share your personal data with third party providers where you have signed up to receiving those third party services as part of our agreement with you, or with your consent.
Third party partners may send marketing material to you, but only with your consent.
For a list of our current third party partners, please click here: https://manypets.com/uk/perks-partners/
If you have consented to marketing from third party partners, you can opt-out by clicking the opt-out link or following the necessary opt-out instructions in the third party partner's marketing correspondence or by contacting them .
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 UK?
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 UK 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 UK. We do this by entering into data-sharing agreements with the recipients of your personal information based outside the UK/ which comply with the UK'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 UK 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, 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.
If you have consented to marketing from third party partners, you can opt-out by clicking the opt-out link or following the necessary opt-out instructions in the third party partner's marketing correspondence or by contacting them.
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.
You have the right to ask that we transfer any personal information 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 information".
You have the right to complain (see further details below under "How can you make a complaint")
Please note that these rights may be limited in certain circumstances, however we will always advise you where there is such a restriction after receiving your request.
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 UK 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.