OTAS Health Care Ltd.’s Privacy Promise:

We at OTAS Health Care Ltd. (referred hereafter as OTHC) are committed to protecting the privacy of our users and customers whilst improving people’s quality of life by enabling them to make healthier choices.
When it comes to health and wellness, we know that one size doesn’t fit all, so we’re committed to helping people eat well, move more, sleep better, think clearer and feel great.
We’re dedicated to a smarter approach to health, and have formed partnerships with outstanding organisations, which enable us to develop market leading insight, expertise and technology.
We believe in being open and up front with users and customers and have developed our Privacy Promise, a quick and simple summary explaining how we manage, share and look after your information.

Our Privacy Promise

We promise to collect, process, store and share your data safely and securely:
• You’re always in control: Your privacy will be respected at all times and we will put you in control of your privacy with easy-to-use tools and clear choices.
• We work transparently: We will be transparent about the data we collect and how use that data so that you can make fully informed choices and decisions.
• We operate securely: We will protect the data that you entrust to us via appropriate security measures and controls. We’ll also ensure through the contracts we have in place, that other businesses we work with are just as careful with your data.
• For your benefit: When we do process your data, we will use it to benefit you and to make your experience better and to improve our products and services.

If you’d like to know more, read our full Privacy Policy below.

Privacy Policy

Our privacy policy will help you understand what information “OTHC” collects, how we use it and what choices you have.

Who we are

• 1. Who are OTHC?
 1.1. “OTHC” (referred to in this policy as “we”, “us” or “our”) is a trading name of:
 o OTAS Health Care Ltd
2 Roper Close
Gillingham
Kent
ME8 9QX

o • 2. Our Data Protection Team

 2.1. “OTHC” have a Data Protection Officer, who can be contacted in the following ways should you have any questions, complaints or feedback about your privacy:
o Email:
Admin@othealth.co.uk
o Mail:
Data Protection Officer
OTHC
2 Roper Close
Gillingham
Kent
ME8 9QX

What personal data we collect and how we use it
 • 3. What data we need and why we need it:
This section tells you what personal data we may collect from you and why we need it when you use our services and what other personal data we may receive from other sources.

3.1. When you register for our services, you may provide us with:
o Your personal details, including your title, name, postal and billing addresses, email addresses, phone numbers, title and date of birth;
o Your payment details;
o Information in relation to your health, including any pre-existing medical conditions;
o Details in relation to your partner, friends or dependents for the purposes of adding them to your plan/policy or in order to create their own. Where customers have provided information about another person the customer should ensure that they have their approval to do so.

3.2. When you contact us, or we contact you or you take part in promotions, competitions, surveys or questionnaires about our services, we may collect:
o Personal data you provide about yourself anytime you contact us about our services (for example, your name, username and contact details), including by phone, email or post or when you speak with us via social media.
o Details of the emails and other digital communications we send to you that you open, including any links in them that you click on.
o Information collected using cookies stored on your device(s) about the use of our online services.
o Your feedback and contributions to customer surveys and questionnaires.

3.3. We will record, and monitor telephone calls made to and from OTHC’s sales and customer service teams. We do this in order to continuously improve our service to customers and for training purposes. This will also include the recording and monitoring of Special Category Data; such as data relating to health and medical conditions. We do not record the segment of telephone calls where any form of payment is being made.

3.4. Special Category Data such as Medical and Health information will be processed using our substantial public interest, under the purpose of Insurance.

• 4. Marketing & Market Research Here we explain the choices you have when it comes to receiving marketing communications and being invited to take part in market research.

4.1. We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously agreed to receive these marketing communications.

4.2. When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing choices online via our marketing preference centre, in My Westfield, over the phone or in writing at any time.

4.3. We also like to hear your views to help us to improve our services, so we may contact you to invite you to take part in market research, called Westfield Insiders. You always have the choice about whether to take part in our market research.

• 5. Understanding our Customers
5.1. We may make use of profiling to produce more relevant and tailored communications by having a deeper understanding of your interests, behaviours and personal preferences. This information helps us provide a better experience for our customers.

5.2. Profiling can help us target our resources more effectively through gaining an insight into the background of our customers and helping us to build relationships that are appropriate to their interests.

5.3. To do this we may use additional external sources of data to increase and enhance the information we hold about you. This may include obtaining details of changes of address, date of birth, telephone numbers and other contact details, information related to your consumption and demographic data generated through software tools such as Cameo or Acorn.

5.4. If you have any questions in relation to how your information is processed, then please contact us using the contact information provided above.

• 6. Processing your data using our Legitimate Interests We have a number of lawful reasons that we can use (or ‘process’) your personal data. One of these lawful reasons is called ‘legitimate interests’. Broadly speaking legitimate interests means that we can process your personal information if: o We have a genuine and legitimate reason and we are not harming any of your rights and interests. The following are some examples of when and why we would use this approach during our normal course of business:

6.1. To improve and enhance our services: When we do process your data, we will use it to benefit you and to make your experience better and to improve our products and services.

6.2. Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.

6.3. Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers.

6.4. Analytics: To process your personal data for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our services and to provide you with the most relevant information as long as this does not harm any of your rights and interests.

6.5. Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.

6.6. Due Diligence: We may need to conduct investigations on existing customers, potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.

6.7. Direct Marketing: We may send postal marketing. We will also make sure our postal marketing is relevant for you and tailored to your interests. You also have the right to opt-out of receiving this information at anytime.

6.8. When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Sharing your personal data

• 7. Third Parties
7.1. In order to provide you with our services, we only share your data with 3rd parties and other organisations within the OTHC Group, in the following circumstances:
o To fulfil your order;
o To provide the benefits and services for which you have applied;
o To verify your identity;
o Authorising debit/credit card payments and any other transactions authorised by the customer;
o To manage and maintain the accuracy of your records;
o To manage the underwriting and/or claims handling procedures (inclusive of your dependents claims) this may include Special Category Data, such as health and medical conditions for all claims processed under your plan;
o To prevent and detect fraud. This will include the recording and monitoring of Special Category data, such as health and medical conditions for all claims processed under your plan;
o To handle complaints and improve customer service; and
o To administer marketing on behalf of OTHC.

7.2. We may also disclose information to third parties or individuals when obliged to by law, for purposes of national security, taxation and criminal investigations.

7.3. We’ll never make your personal data available to anyone outside OTHC for them to use for their own marketing purposes without your prior consent.