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PROFESSIONAL BUSINESS PRIVACY POLICY

Last updated: May 2018

Protecting your personal information is extremely important to Legal & General.
It’s especially important for a large financial company like ours, as our
customers and professional business clients trust us to look after a huge amount
of sensitive information on everything from their business affairs to their
medical history.

The way we collect and share your information is equally important. Our
professional business clients expect us to manage their information privately
and securely. If we don’t, they’ll lose trust in us.

This policy tells you how we collect and process your personal business
information. Please take a few minutes to read it, and show it to anyone else
connected to the business relationship.


WHAT DOES THIS POLICY COVER?

This privacy policy relates to individuals working for/as businesses who enter
into agreements with us (e.g. intermediaries, employer broker consultants,
trustees and employers).  We have a separate privacy policy for retail
customers, which can be found on our website.


WHAT IS PERSONAL INFORMATION?

When we talk about personal information we mean information about an individual
that can identify them, like their name, address, e-mail address, telephone
number and financial details. It can relate to customers, employees,
shareholders, business contacts and suppliers. Any reference to “information” or
“data” in this policy is a reference to personal information about a living
individual.


WHAT INFORMATION DO WE HOLD?

We may collect and process the following personal information about you. In most
cases this will be limited to business information that relates to you, how
these have an impact on our products and services that may be of interest to you
and how we manage our relationship:

Type of data Description Examples of how we use it Contact
 * Who you are
 * Where you live
 * How to contact you

 * Managing and servicing our business relationship
 * Business to Business marketing
 * Analysis
 * Enhancing our product and service offering

Personal Details
 * Age
 * Gender
 * Family details
 * Visual images & personal appearance
 * Financial Details
 * Lifestyle and social circumstances

 * Managing and servicing our business relationship
 * Business to Business marketing
 * Analysis

Transactional
 * How you may use our products and services 

 * Managing and servicing our business relationship
 * Making sure our products and services are fit for purpose
 * Analysis
 * Enhancing our product and service offering

Contractual
 * Your creditworthiness (if applicable)

 * Managing and servicing our business relationship

Preferences
 * Ways you want us to market to you

 * Business to business marketing

Technical
 * Details on the devices and technology you use

 * Making sure our products and services are fit for purpose

Open data & public records
 * Other information about you that is openly available on the internet

 * Managing and servicing our business relationship
 * Business to business marketing

Documentary data & national identifiers
 * Company details
 * National Insurance number

 * Managing and servicing our business relationship
 * Compliance with statutory regulations and to prevent financial crime


WHERE DO WE GET OUR INFORMATION FROM?

 * Information you give us directly (when you fill in forms or contact us by
   phone, e-mail etc.).
 * Information we collect about you or receive from other sources. This could be
   information you provide to us electronically (through our website or an
   online portal, for example), information we get from a third party or from
   publicly available sources such as regulatory bodies (e.g. FCA, Companies
   House etc). For more information on how we use cookies, please check the
   cookie policy link in the foot of this page.


HOW DO WE USE YOUR INFORMATION?

We use personal information that we hold about you:

 * To carry out our responsibilities resulting from any business or commercial
   agreements you’ve entered into with us and to provide you with the
   information, products and services that you’ve asked from us.
 * To provide you with business to business marketing information about services
   and products we offer across the Legal & General Group which may be of
   interest to you.
 * To tell you about changes to our services and products.
 * To comply with any applicable legal or regulatory requirements (including to
   comply with any applicable regulatory reporting or disclosure requirements).
 * For carrying out market research, statistical analysis to help us to improve
   our processes, products and services and generate new business (e.g. to
   understand digital behaviours, identify financial attitudes and develop more
   engaging communications).
 * To run our business in an efficient and proper way. This includes testing our
   systems, managing our financial position, business capability, planning,
   communications, corporate governance, and audit.
 * For any other purpose that we’ve agreed with you from time to time.


USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS

Data protection laws require us to meet certain conditions before we’re allowed
to use your personal information in the way we describe in this privacy policy.
We take these responsibilities extremely seriously. To use your personal
information, we’ll rely on the following conditions, depending on the activities
we’re carrying out:

 * Providing our contracts & services to you: We’ll process your personal
   information to carry out our responsibilities resulting from any commercial
   agreements or contracts you’ve entered into with us and to provide you with
   the information, products and services you’ve asked from us, which may
   include online services.
 * Complying with applicable laws: We may process your personal information to
   comply with any legal obligation we’re subject to.
 * Legitimate interests: To use your personal data for any other purpose
   described in this privacy policy, we’ll rely on a condition known as
   "legitimate interests". It’s in our legitimate interests to collect your
   personal data as it provides us with the information that we need to provide
   our services to you more effectively. We may use your information to:
    * Carry out market research and product development.
    * We may provide you with business to business marketing information about
      our services or products. You may object to this type of marketing at any
      time by e- mailing or telephoning your customer servicing team.
      Alternatively, you can use the Contact Us section of our consumer website
      or the adviser, employer or institutional websites. Details of all other
      Legal & General websites can be found on our Group website.
    * Develop and test the effectiveness of marketing activities.
    * Develop, test and manage our brands, products and services.
    * Study and also manage how our professional business clients use products
      and services from us and our business partners.
    * Manage risk for us and our retail customers.

This requires us to carry out an assessment of our interests in using your
personal data against the interests you have as a citizen and the rights you
have under data protection laws.

The outcome of this assessment will determine whether we can use your personal
data in the ways described in this privacy policy. We’ll always act reasonably
and give full and proper consideration to your interests in carrying out this
assessment.

 * Consent: We may process your personal information for different purposes
   where you’ve provided your consent to do so (e.g. collecting your preferences
   when we plan and host conferences and seminars).
 * Criminal Conviction Data: We may process this type of information solely for
   the purpose of preventing fraud.

Please be aware that the personal information you provide to us, and which we
collect about you, is required for us to be able to provide our services to you
and without it we may not be able to do so.


HOW LONG DO WE KEEP YOUR INFORMATION FOR?

We’ll keep your personal information in accordance with our internal retention
policies. We’ll determine the length of time we keep it for based on the minimum
retention periods required by law or regulation. We’ll only keep your personal
information after this period if there’s a legitimate and provable business
reason to do so.


WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We’ll only disclose your information to:

 * Other companies within the Legal & General Group, third-party suppliers,
   contractors and service providers for the purposes listed under “How do we
   use your information” above.
 * Our regulators, government (e.g. HMRC) and law enforcement or fraud
   prevention agencies.

Additionally, we may disclose your personal information to third parties:

 * In the event that we sell or buy any business or assets, in which case we’ll
   disclose your personal data to the prospective seller or buyer of such
   business or assets.
 * If we, or substantially all of our assets, are acquired by a third party, in
   which case personal data held by us about our professional business clients
   will be one of the transferred assets.
 * If you have been dealing with a financial adviser (e.g. employer broker
   consultant), we’ll provide information about your product and, where
   appropriate, with other information about your dealings with us, to enable
   your adviser to give you informed advice.
 * In order to enforce or apply the terms of any contract with you.
 * If we’re under a duty to disclose or share your personal data in order to
   comply with any legal obligation or regulatory requirements, or otherwise for
   the prevention or detection of fraud or crime.
 * To protect you and Legal & General from financial crime, Legal & General may
   be required to verify the identity of new and sometimes existing professional
   business clients. This may be achieved by using reference agencies to search
   sources of information relating to you (an identity search). This will not
   affect your credit rating. If this fails, Legal & General may need to
   approach you to obtain documentary evidence of identity.
 * In accordance with the terms of business agreement, we may perform credit
   checks on certain types of professional business clients (e.g. directors of
   intermediary firms).


FRAUD PREVENTION

Legal & General may need to check your details with fraud prevention agencies
(e.g. we have to screen at firm and director level of anyone we remunerate). If
false or inaccurate information is provided and fraud is identified details will
be passed to fraud prevention agencies. Law enforcement agencies may access and
use this information. We may also share information about you with other
organisations and public bodies, including the police and we may check and/or
file your details with fraud prevention agencies and databases.

Legal & General and other organisations may also access and use this information
to prevent fraud and money laundering, for example, when:

 * Checking details on applications for credit and credit related or other
   facilities.
 * Managing credit and credit related accounts or facilities.
 * Recovering debt.
 * Checking details on proposals and claims for all types of insurance.
 * Checking details of professional business clients, job applicants and
   employees.

Legal & General and other organisations may access and use from other countries
the information recorded by fraud prevention agencies. Please contact our Group
Financial Crime department if you wish to receive the relevant details of the
fraud prevention agencies:

Address: Group Financial Crime, 7th Floor, Brunel House, 2 Fitzalan Road,
Cardiff CF24 0EB


TRANSFERRING YOUR DATA OUTSIDE THE EU

The data that we collect from you may be transferred to, and stored at, a
destination outside the European Economic Area (“EEA”) to third-party suppliers,
delegates or agents. We’ll take all reasonably necessary steps to make sure that
your data is treated securely and in accordance with this privacy policy.

We’ll only transfer your data to a recipient outside the EEA where we’re
permitted to do so by law (for instance, (A) where the transfer is based on
standard data protection clauses adopted or approved by the European Commission,
(B) where the transfer is to a territory that is deemed adequate by the European
Commission, or (C) where the recipient is subject to an approved certification
mechanism and the personal information is subject to appropriate safeguards,
etc.).

Unfortunately, sending information via e-mail is not completely secure; anything
you send is done so at your own risk. Once received, we will secure your
information in accordance with our security procedures and controls.


YOUR RIGHTS

You have rights under data protection law that relate to the way we process your
personal data. More information on these rights can be found on the Information
Commissioner’s website. If you wish to exercise any of these rights, please get
in touch with your relationship manager or your customer services team.
Alternatively, you can use the Contact Us section of our consumer website or the
adviser, employer or institutional websites. Details of all other Legal &
General websites can be found on our Group website. 

 

Your rights  1. The right to access the personal data that we hold about you.
 2. The right to make us correct any inaccurate personal data we hold about you
 3.

The right to make us erase any personal data we hold about you. This right will
only apply where for example: 

 * We no longer need to use the personal data to achieve the purpose we
   collected it for
 * You withdraw your consent if we’re using your personal data based on that
   consent
 * Where you object to the way we use your data, and there is no overriding
   legitimate interest 

 4.

The right to restrict our processing of the personal data we hold about you.
This right will only apply where for example:

 * You dispute the accuracy of the personal data we hold 
 * You would like your data erased, but we require to hold it in order to stop
   its processing
 * You have the right to require us to erase the personal data but would prefer
   that our processing is restricted instead
 * Where we no longer need to use the personal data to achieve the purpose we
   collected it for, but you need the data for legal claims.  

 5. The right to object to our processing of personal data we hold about you
(including for the purposes of sending marketing materials to you).  6. The
right to receive personal data, which you have provided to us, in a structured,
commonly used and machine-readable format. You also have the right to make us
transfer this personal data to another organisation.  7. The right to withdraw
your consent, where we’re relying on it to use your personal data.

 


CONTACTS AND COMPLAINTS

If you have any questions about this privacy policy or wish to exercise any of
your rights, please get in touch with your relationship manager or customer
services team. Alternatively, you can use the Contact Us section of our consumer
website or the adviser, employer or institutional websites. Details of all other
Legal & General websites can be found on our Group website.

If you have any concerns about the way we process your personal data, or are not
happy with the way we’ve handled a request by you in relation to your rights,
you also have the right to make a complaint to the Information Commissioner's
Office. Their address is:

First Contact Team
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF


DATA PROTECTION OFFICER

Legal & General has appointed a Data Protection Officer to provide independent
expert advice and monitor compliance with data protection laws:

Name: Liz Bradley

E-mail address: Data.Protection@landg.com

Address: 1 Coleman Street, London, EC2R 5AA


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