Survey Privacy Policy

1. INTRODUCTION

1.1 The MOODY App is brought to you by We Are Moody Limited (“MOODY”, “our”, “we” or “us”). 

This privacy statement explains how we use your personal data as a respondent to a questionnaire / survey, or participant in a focus group offered on behalf of our partner Reinsurance Group of America, Incorporated (“RGA”).

1.2 We and RGA are committed to protecting and respecting your privacy. We ask that you read this Privacy Statement carefully as it contains important information about what personal information we may collect from you and how we will use it. Questions, comments and requests regarding this Privacy Statement are welcomed and should be sent to [email protected].

2. ABOUT US

2.1 We Are Moody Limited is a company registered in England and Wales with company registration number 10047636. Our registered office is at 24 Greville Street, Farringdon, London, EC1N 8SS. 

Reinsurance Group of America, Incorporated is the holding company of a group of companies which operate globally focusing on life- and health-related reinsurance solutions. The following RGA entities will engage in the processing of information: RGA UK Services Limited with company registration number 03086510 and RGAX EMEA Limited with company registration number 11113491, both located at 5 Aldermanbury Square, 16th Floor, London EC2V 7HR.

For the purpose of the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act 2018 (together “Data Protection Legislation”), we are the ‘data processor’, (i.e. the company which processes personal data on behalf of the controller), and RGA is the ‘data controller’ that determines the purposes and means of the processing of your personal data.

2.3 Our Data Protection Officer is Louise Marshall of Dragon Argent Limited. She can be contacted at [email protected]. 

RGA’s Data Protection Officer is Dean Scotson. Should you have any questions or concerns regarding the way in which your personal information has been used, please contact him at [email protected]. 

3. WHAT INFORMATION DO WE COLLECT?

3.1 If you take part in this survey and/or focus group we will collect and process the following data about you:

  1. Account information, including your name, username, and e-mail address 
  2. Consumer behaviour and purchase patterns
  3. Attitudes and approach to healthcare and wellness
  4. Lifestyle information, such as frequency of exercise, energy levels, sleeping habits
  5. Insurance purchase patterns and experiences in relation to insurance products

Please note that only limited amount of this personal data will be provided to RGA. The information that we will disclose to RGA will be anonymised, meaning it will not be used in a manner which would allow your identification and determination of your individual responses. 

4. WHY DO WE COLLECT THIS INFORMATION?  

4.1 The information we collect is primarily used to provide RGA with audience profiling and marketing insights consultancy services as part of our business with research institutions. 

RGA uses the anonymised data that we provide for market research purposes intending to determine the audience’s interests in insurance products. 

4.2 We also use information that we collect about you for operational purposes, including to:

  1. provide customer services, responding to your enquiries, fulfilling any of your requests for information; 
  2. comply with applicable laws, to enforce our rights or to respond to requests from law enforcement and other government authorities.


4.3 We use your personal data pursuant to one or more of the following legal bases as prescribed by Data Protection Legislation:

  1. where it is in our or RGA’s legitimate interest to do so and we have indicated to you what that interest is (per 4.1 and 4.2 above); 
  2. to comply with a legal obligation; and 
  3. where you opted in the processing of your personal data for a specific purpose, such as permitting us to collect and use your personal data for research purposes of our partners, such as RGA.


5. WHO WE MIGHT SHARE YOUR INFORMATION WITH?

5.1 We will never share or sell your personal information to any third parties except in the ways described below, or with your consent:

  1. Suppliers. We employ other companies and individuals to perform functions on our behalf, including data analytics and other IT suppliers (for example, MailChimp). We do not share your personal information with our agents or suppliers except as is necessary in order to enable them to provide us with a service and then only pursuant to our express instructions.
  2. Other reasons. We may also share your personal information with a purchaser or potential purchaser of our business and in some circumstances, we may have to disclose your personal information by law, either because a court or the police or other law enforcement agency has asked us for it, to enforce our legal rights, or to prevent fraud.


6. WHERE DO WE STORE YOUR INFORMATION?  

6.1 The data that we collect from you will be stored and processed in the United Kingdom.

7. SECURITY AND INFORMATION RETENTION

7.1 We take all steps reasonably necessary to ensure that your personal data is treated securely. In particular, all information you provide to us is stored on our supplier’s secure servers (including within the ‘cloud’). We will also anonymise your personal information before sharing it with RGA (where you have permitted us to share such data). You should be aware, however, that the transmission of information via the Internet is not completely secure.

7.2 Unless you are exercising certain specific legal rights, we will continue to hold your personal information for a period of no longer than 24 months after the date on which you complete the survey or, if relevant, for as long as is necessary to comply with any legal obligations.

8. YOUR DATA RIGHTS  

8.1 You may have the following rights:

You may request details of the personal information that we hold about you under Data Protection Legislation. If you would like a copy of the information held about you, please write to us at [email protected].

8.2 If you think any information we have about you is incorrect or incomplete, please write to us or email us at [email protected] as soon as possible. We will correct or update any information as soon as reasonably practicable.

8.3 You may have additional rights in relation to our handling of your personal data under Data Protection Legislation. For example, the right to have your personal data erased, the right to object to or restrict us from processing your personal data, and the right to data portability. If the legal basis for our processing your personal data or special category data is consent or explicit consent, as appropriate, you have the right to withdraw your consent at any time. Please note that if you withdraw your consent, the lawfulness of any processing undertaken before such withdrawal will not be affected. If you would like to exercise any of these rights at any time, please write to us or email us at [email protected]. Please be aware that we will have to verify your identity before we respond to any such request.  

8.4 Should you have any complaints about how we handle your personal information, please contact us at [email protected]. Should we be unable to resolve your complaint and you wish to take your complaint further, you may do so by contacting the UK Information Commissioner’s Office. 

9. CHILDREN’S PRIVACY  

9.1 We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected]

10. UPDATES TO THIS PRIVACY STATEMENT

10.1 If we make material changes to this Privacy Statement, we will notify you by email. 

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