Competitions data protection statement

This document is AXA’s Data Protection Statement for Competitions. It contains all the information you need to understand how we use your data when we carry out competitions, draws and other promotional activities (called ‘competitions’ in this document).

Company information

References to “AXA”, “us”, “our” and “we” mean AXA Holdings Ireland Limited and its subsidiaries, including AXA Insurance dac (the ‘data controller’), and any associated companies from time to time. More information about AXA can be found at either www.axa.ie or www.axani.co.uk.

Use of information

Where you submit an application to enter a competition, we will use your personal data to enter you into that competition and to judge or evaluate your entry or to carry out a draw. We will also use the information you provide to make contact with you (such as to resolve any issues or to notify you where you have been successful) and, where applicable, to arrange for delivery of any prizes. All entries to competitions will be subject to this data protection statement and the terms and conditions of the competition in question.

Sometimes in competitions there is associated marketing activity. The sending of marketing material to you is only done in circumstances where you have provided us with your consent in advance. If there is an associated marketing aspect to the competition, consent will be sought on the entry form for the competition. If there is no marketing aspect, there will be no request for consent on the entry form for the competition.

For more information on the use of personal data in marketing, please visit https://www.axani.co.uk/axa-insurance-marketing-preferences/.

Purposes and Legal Bases for processing data

We may use the personal data we gather for any or all of the following purposes:

  1. to carry out competitions, draws and other promotional activities;

    Legal Basis:

    • the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. The contract between us is set out in the terms and conditions of the relevant competition.

  2. to verify your identity in any interactions between AXA and you;

    Legal Basis:

    • the processing is necessary for compliance with a legal obligation to which the controller is subject.

  3. to verify the accuracy of the information we receive;

    Legal Basis:

    • the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

  4. for statistical analyses, market research and the review and improvement of AXA’s products, services, processes, systems, websites and apps. Where possible we will anonymise the data we analyse;

    Legal Basis:

    • the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. AXA’s legitimate interest is to engage in activities to improve and adapt its activities and to help our business grow and to ensure that our systems are effective and efficient.

  5. to inform you of other products and services that may be of interest to you. The sending of marketing material to you is only done in circumstances where you have provided us with your consent in advance;

    Legal Basis:

    • the data subject has given consent to the processing of his or her personal data for one or more specific purposes.

  6. for staff training, performance reviews and discipline;

    Legal Basis:

    • the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. AXA’s legitimate interest is to engage in activities to ensure that our systems are effective and efficient;
    • the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

  7. for the detection and prevention of fraud, money laundering and other offences and to assist the police or any other authorised investigatory body or authority with any inquiries or investigations;

    Legal Basis:

    • the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. AXA’s legitimate interest is to investigate and prevent potential fraudulent and other illegal activity;
    • the processing is necessary for compliance with a legal obligation to which the controller is subject;
    • the processing is necessary for the performance of a task carried out in the public interest.
Effect of not providing information

If you do not provide the information that is needed to enter a competition, the result will be that your entry may be disqualified from or may not be accepted into the competition (in accordance with the terms and conditions of the competition in question).

Call Recording

If the competition you enter involves telephone calls between us, please be aware that we may record or monitor these telephone calls in order to ensure accuracy in our records, to facilitate staff training, for the prevention of fraud, for management of complaints and to improve customer satisfaction.

Sharing of information with third parties

We may choose to have certain services relating to competitions provided by carefully selected third parties. In such circumstances, we take precautions regarding the practices employed by the service provider to ensure your personal data is stored and processed legally and securely.

International data transfers

AXA complies with the law regarding international transfers of data by relying on the European Commission’s standard data protection contract clauses, Binding Corporate Rules or the decisions of the European Commission stating that certain countries ensure adequate levels of data protection in their law.

If you would like more information about the relevant safeguards involved in the transfer of personal data to countries or companies outside the European Economic Area, please visit the European Commission’s website on data transfers outside the EU or contact us using the details at the end of this page.

Type of data collected for competitions

The exact categories of data that we gather will be different for each competition. However, we feel that it is important that you know what types of information that we gather and use. Therefore, the types of data collected set out below are non-exhaustive and only give an indication of the data we may gather about you for a competition. The entry form or the terms and conditions of the specific competition you enter may also contain more details about what data is being processed.

Examples of the types of data collected

Name, address (including Eircode), date of birth, contact details, telephone recordings, marketing preferences and renewal dates of policies with other insurers, answers to questions, whatever other information is requested in the competition entry form.

Please feel free to contact us (details below) if you would like more information about the precise information we gather and use.

Retention of your personal information

The amount of time information is retained will depend on the nature of the competition. The period of time will not exceed 7 years. However, it is likely to be far shorter (possibly as little as one year).

Where the personal data we gather is also required for an insurance policy or other dealings with us, the retention periods for this data will be the same as for customer policy data (please see the ‘More Information’ section below for further details).

Your Rights

As a ‘data subject’, you have the following rights in relation to your personal data:

  1. to withdraw consent where we are processing your information on the legal basis of consent;
  2. of access to the personal data concerning you that we hold and to be informed why and how we process that data;
  3. to require us to correct any inaccurate information about you (including missing details);
  4. of erasure/right to be forgotten, which means you have a right to have personal data concerning you erased. However you may only request the deletion of your data in specific situations;
  5. to data portability, which means you may request from us all personal data that you provided to us. You may also request that we send this data to another company or person;
  6. to object to the processing of your personal data, where we do so in the public interest or on the basis of a ‘legitimate interest’ (although these bases are not generally relied upon for competitions). We will then stop processing the personal data in question unless we can demonstrate compelling legitimate grounds for the processing that override your right or unless we need to use it in a legal claim;
  7. to restrict processing of your personal data where you feel that it is inaccurate, that we are processing it unlawfully or that we no longer need it or where you have invoked your right to object (as set out in paragraph (f) above);
  8. to lodge a complaint with a data protection regulator, such as the Data Protection Commission. The DPC’s contact details can be found at dataprotection.ie.

Please send all requests to us (details below) in writing, by either post or email.

More information

We reserve the right to change the contents of this Data Protection Statement from time to time at our sole discretion.

For details on your other rights and how we use your personal data in contexts other than competitions, please see our Data Protection Statements at www.axani.co.uk/axa-insurance-data-protection/ or contact us using the details below.

Contact information

If you are unhappy with the way we have handled your personal information and wish to make a complaint or if you simply want further information about the way your personal data will be used, please contact us by any of the following options: