Privacy Policy

1. Introduction

This Discovery Hub Community Privacy Policy applies to users ("you") who access and use the Aviva Discovery Hub Community (the "site"). It explains how we use Personal Information that you provide on the site when you become a community member and participate in Discovery Hub surveys and/or research studies ("surveys").

This Privacy Policy supplements the Privacy Policy relevant to your Aviva product and should be read in conjunction with that document.

Aviva uses a third party service provider, Toluna Holdings Limited ("Toluna")" to host the site on its online platform. Toluna manages the site and processes Personal Information collected from you through the Discovery Hub on behalf of Aviva. For more information about Toluna, please see section 4 (Who Personal Information is shared with) below.

This Privacy Policy is issued on behalf of the Aviva group companies within the United Kingdom. When we refer to " Aviva", "we", "us" or "our", we mean the relevant company in the Aviva group that processes your Personal Information. Aviva Life & Pensions UK Limited is the main company responsible for your Personal Information (known as a "controller"). If you have any questions about this, please contact us using the details set out in section 11 (Contact us) below.

If you provide us with Personal Information about someone else, we'll assume that you have their permission, where required. We'll process Personal Information about such individuals according to this Privacy Policy so it may be helpful to show them this Privacy Policy and, if they have any concerns, please contact us using the details set out in section 11 (Contact us) below.

2. Personal Information we collect and how it is used

a. Sources of Personal Information

When you complete the registration form on the site, agree to become one of our community members and/or participate in surveys, Toluna receives Personal Information directly from you. We may also use Personal Information we already hold within the Aviva group about you and your products.

b. Types of Personal Information we may process

Information provided by you or information already held by Aviva, including:

  • General data - includes your name (includes first and last names), date of birth, marital status, housing status, household size and education.
  • Contact data - includes your address, e-mail address and telephone number.
  • Identification data - includes panellist ID and username.
  • Appearance and behaviour data- includes your gender, age, interests, preferences, feedback and survey responses, demographic and behavioural data.
  • Product data- includes information relevant to your product, including product type, pension pot size, pension contribution level, years contributing and whether you're an active or deferred member of the relevant pension scheme.
  • Employment-related data - includes employment status, employer and industry.
  • Financial data- includes details of income and financial situation.

Sensitive Personal Information - may include ethnic or racial origin, health and sexual orientation. We may from time to time ask you to provide us with Sensitive Personal Information about yourself, such as information about your health, sexual orientation and racial or ethnic origin. It is your choice whether to provide this information.

Information collected from your devices, including:

  • Internet protocol (IP) addresses, login data, browser, location, browser plug-in types, operating system and platform and other technology on the devices you use to access this website.

c. Uses of Personal Information

Being a Community Member

Aviva and Toluna use your Personal Information for:

  • Conducting market research and collecting user feedback, e.g. collecting survey results to assist us to improve and develop our products and services;
  • Contacting you for any reason connected with your community membership;
  • Incentive fulfilment - when you earn incentive points through your participation in the surveys, the points are deposited into your account. When you wish to redeem them, we will use your Personal Information to send you your rewards;
  • Sending you invitations for your participation in surveys - to ask you if you are interested in participating in our upcoming surveys. We may also make you aware via your online panel community membership account of surveys you may be suitable to participate in, based on information we hold about you;
  • Understanding more about your survey responses and the insights you provide us - we share Personal Information with our platform provider (Toluna) so we can understand more about your survey responses;
  • Statistical purposes -Toluna carries out data analysis to help Aviva understand its customers better and to help Aviva improve and develop its products and services.

Toluna uses your Personal Information for matching you with appropriate surveys to see if you qualify for particular surveys.

We match and link the Personal Information collected about you on the site with data we previously collected about you.

3. Lawful bases for uses of Personal Information

We are committed to collecting and using your Personal Information in accordance with applicable data protection laws. By law, we must have a legal justification, known as a "lawful basis", to use your Personal Information for each of the purposes described in this Privacy Policy. Our lawful bases are:

  • Consent - in certain cases, we collect and process your Personal Information, e.g. when we process your Sensitive Personal Information.
  • Legitimate interests - when we require your data to pursue our legitimate interests, e.g. when you participate in surveys, when we conduct customer satisfaction research by getting your feedback on Aviva's products and/or services.
  • Performance of a contract - in some circumstances, we may need to process your Personal Information to comply with a contractual obligation, e.g. when we use your Personal Information to send you your rewards or points.
  • Compliance with a legal obligation - to meet responsibilities we have to our regulators, tax officials, law enforcement, or other legal responsibilities.

For further information about what these lawful bases mean, please see the Privacy Policy relevant to your Aviva product(s).

4. Who Personal Information is shared with

Aviva has appointed Toluna to host the site on its online platform for it. Toluna builds and manages the site and processes all Personal Information we collect from you as part of your community membership. Aviva requires Toluna to respect the security and confidentiality of your Personal Information and to treat it in accordance with the law. Aviva does not allow Toluna to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

In connection with the purposes set out above, Toluna may need to transfer Personal Information to a related company that is located outside of the UK. Toluna ensures that adequate safeguards in place for transfers of Personal Information outside the UK. This may include transfers to countries that the UK considers will provide adequate levels of data protection for your Personal Information (such as countries in the European Economic Area) or putting contractual obligations in place with the party Toluna is sending information to.

Aviva will sometimes share Personal Information with Aviva group companies and other third parties. Some of the organisations Aviva shares information with may also be located outside of the UK. For further information on international data transfers by Aviva, please see the section on International Data Transfers in the Privacy Policy relevant to your Aviva product(s).

5. Cookies Toluna uses on the site

Cookies are used on the site to ensure the site works properly and enable you to move around the site and use its features, such as enabling you to log on to secure areas of the site. For detailed information on the cookies and similar technologies used and the purposes for which they are used, see Toluna's Cookie Policy here.

6. Our incentive points policy

Community members receive points for their participation in surveys. For more information about earning and redeeming points, please visit our Terms and Conditions page.

7. Links

From time to time we may offer visitors the ability to voluntarily link to other sites. We do not review and are not responsible for the content or effect of the privacy policies of these sites.

8. Children's privacy

Aviva and Toluna will not knowingly collect any information online from any child under the age 18. Toluna complies with the EU "Safer Internet programme", the General Data Protection Regulation, UK Data Protection Act and the ESOMAR guidelines in relation to online surveys concerning children and young people.

9. Data rights

You have legal rights under data protection laws in relation to your Personal Information. For more information see the section on Data Rights in the Privacy Policy relevant to your Aviva product(s).

a. How to access, update, correct or delete your Personal Information on the site

You may access, correct, or request deletion of your Personal Information, or terminate your membership by logging into your Community Account, selecting "Contact us" in the site footer and sending Toluna a message using the contact form. By selecting "My Profile" and following the appropriate directions, you can update your Personal Information in your member account. If you have any questions about how to access your Personal Information on the site you may contact us by email at discoveryhub@tolunainsights.com.

b. How to end your Community membership

If you choose to end your community membership or require us to cease processing your Personal Information you may discontinue your membership by going to your account and selecting "Unsubscribe" in the footer. By following the appropriate directions, your record will be marked as "do not contact", and you will no longer receive invites to participate in future Surveys from Toluna. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. In most cases it will take 2 to 3 days to process this change, but please allow up to two full weeks for your status to be finalised. Please note that you may continue to receive communications during this short period after changing your preferences while our systems are fully updated.

You may also send an email directly to discoveryhub@tolunainsights.com requesting to be removed from the Discovery Hub.

If you decide to end your membership, Toluna and Aviva will no longer use your Personal Information to contact you about the Discovery Hub, but may retain your data in accordance with backup procedures and data retention policies.

10. Updates

This Privacy Policy is updated from time to time to take account of changes in our business activities, legal requirements and to make sure it's as transparent as possible, so please check back here for the current version. You can see when this Privacy Policy was last updated by checking at the top of this page.

11. Contact us

If you have any questions about this Privacy Policy or how to exercise your rights, please contact Aviva's Data Protection Officer:

Write to: The Data Protection Team, Aviva, PO Box 7684, Pitheavlis, Perth PH2 1JR

Email us: DATAPRT@aviva.com

If you'd like to submit a data subject request in relation to the Discovery Hub, please log into your Community Account, select "Contact us" and use the contact form to contact Toluna. Alternatively, you may email Toluna at: discoveryhub@tolunainsights.com .

If you're not happy with the way we're handling your Personal Information, you have a right to make a complaint with your local data protection supervisory authority at any time. In the UK this is the Information Commissioner's Office (ICO). We ask that you please attempt to resolve any issues with us before contacting the ICO.