Protecting your personal information is extremely important to us at Legal & General. It’s especially important for a large financial company like ours, as our customers 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, use, store and share your information is equally important. Our customers expect us to manage their information privately and securely. If we don’t, they’ll lose their trust in us.

This policy tells you how we collect and process your personal information when you enter the competition “your colourful retirement” (the “competition”). Please take a few minutes to read this policy, and ensure that you show and/or explain it to any other people in your competition entry photo (such as friends and family). From time to time we may make changes to this privacy policy to ensure that it is accurate and up to date and to reflect any changes in the law.

(a) About us

We are Legal & General Assurance Society Limited of One Coleman Street. Any references in this privacy policy to “we”, “our”, “us” etc will be interpreted as a reference to us.

(b) What does this policy cover?

This privacy policy relates to entrants to the competition and other individuals who are included in the entrant’s competition entry photo.

(c)  What is personal information?

When we talk about personal information we mean information about an individual that can identify them, like their name, address, email address, telephone number and financial details. It can relate to customers (including prospective customers), competition entrants and other individuals that competition entrants involve in their competition entries (such as friends and family who are included in your competition entry photo), 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.

(d) What information do we hold?

We may collect and process the following personal information about you:

Type of data

Description

Examples of how we use it

Contact
  • Who you are
  • How to contact you (e.g. email address and postal address)
  • Running the competition
  • If you are a winner, we may contact you in relation to exhibition(s) and/or L&G marketing  or corporate campaign(s)
Personal details
  • Competition entry details
  • Visual images and personal appearance (when you submit your photo to us)
  • Running the competition
  • If you are a winner, we may use your photo in exhibition(s) and/or L&G marketing or corporate campaign(s)


(e) Where do we get our information from?

  • Directly from you – information you provide when you fill in forms or contact us by phone, email etc.
  • Information we collect about you or receive from other sources. This could be information you provide to us as part of your competition entry, and could include information about any individuals identifiable in your photo. Please refer to our cookie policy for more information on how we use cookies on our website.


(f) How do we use your information?

We use personal information that we hold about you:

  • To run the competition and related activities fairly and properly. For example, if your competition entry is a winner, we will contact you to tell you the good news and we may also include your winning photo in exhibition(s) and/or L&G marketing or corporate campaign(s).  
  • To carry out our responsibilities resulting from any agreements you’ve entered into with us (such as the photo release form, if your photo is selected) and sending out the Gift Card if you are a winner, via a fulfilment agency.
  • To comply with any applicable legal or regulatory requirements (including to comply with the CAP Code for promotional marketing).
  • For any other purpose that we’ve agreed with you from time to time.


(g) Using your information in accordance with data protection laws


Data protection laws require us to meet certain lawful bases 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 lawful bases, 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 agreements you’ve entered into with us (such as the photo release form, if your photo is selected).
  • Complying with applicable laws: We may process your personal information to comply with any legal obligation or guidance we’re subject to (such as the CAP Code).
  • 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 operate our business and provide our services to you more effectively. We may store and process your information under Legitimate Interests to:
    • Run the competition fairly and properly
    • Tell you if your competition entry is a winner

If your photo is selected and you send us the required and completed release forms, we will use your information to:

  • Include winning entries in exhibition(s) and/or L&G marketing or corporate campaign(s)  
  • Send you your Gift Card

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.

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 run the competition, and without it we may not be able to consider your competition entry.

(h) How long do we keep your information for?

If your photo is selected and you supply the required, completed release forms, we will retain your personal information for five years, until May 2024 so that any material that they are used in can be fully utilised

If your competition entry photo is not selected as one of the winning photos or you do not supply the required, completed release forms by 25 August 2019, we will securely delete it from our systems by 8 September 2019, together with any other information you submitted as part of your competition entry.

(i) 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.

For example:

  • If your competition entry is shortlisted, we will share it with our panel of judges.
  • If your competition entry is a winner, we may share your photo with third-party suppliers. For example, the creative, design, digital, print or marketing agencies that will use the photo to create corporate, promotional and marketing material. We’ll also share the selected winning photos in order to include your photo in exhibition(s) and/or Legal & General corporate, promotional or marketing campaign(s).
  • If your competition entry is a winner, we will share your photo, full name, address and contact details with a fulfilment agency, which will send out the Love2Shop Gift Card on our behalf. 


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

  • In order to enforce or apply the terms of any contract with you (such as the photo release form, if your photo is selected).

(j) 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.).  If you would like further information on these safeguards, please contact us.

Unfortunately, sending information via email 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.

(k) 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, Contact Us .

Your rights:

1 The right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this privacy policy.
2 The right to access the personal data that we hold about you.
3 The right to make us correct any inaccurate or incomplete personal data we hold about you.
4

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.
  • Where you object to the way we use your data, and there is no overriding Legitimate Interest
5

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.  
6 The right to object to certain types of processing (including for the purposes of sending marketing materials to you).


(l) Contacts and complaints


If you have any questions about this privacy policy or wish to exercise any of your rights, including changing your marketing preferences, Contact Us 

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 (see www.ico.org.uk for more information). Its address is:

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

(m) 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 Gaspar

Email address: Data.Protection@landg.com

Address: 1 Coleman Street, London, EC2R 5AA