Using our service means that you’ve read and agreed to what’s written here, so please take a moment to go over it.
We will never, ever, not in a million years, sell your data to others, or use it for purposes other than our main business!
Keeping your personal information secure is incredibly important to us, and we invest a lot of effort in protecting it.
We only collect information in accordance with the applicable data protection law that we’ll need to conduct our business, improve our products, provide adequate pricing, help us with marketing and prevent fraud.
For that, we collect data such as general location, network information and other indicators.
And now, for the legal version...
Last updated: September 2020
Responsibility for the personal data processing falls on
Lemonade Insurance N.V.
Korte Leidsedwarsstraat 12-16, 1017 RC Amsterdam, Netherlands
Manager: Jonathan Jaffe
Email: [email protected]
Where this data protection declaration speaks of “we” or “us”, this relates in each case to the aforementioned company.
Our Data Protection Officer can be contacted via the email set out above.
We only process your personal data in compliance with the data protection regulations, where a statutory provision allows us to do so, or where you have granted consent. This also applies during the processing of personal data for marketing and advertising purposes.
In the scope of our Internet Services, we also collect information that, taken as such, does not allow any identification of you in person. In certain cases – in particular in combination with other data – this information may still be regarded as “personal data” in the sense of the data protection laws. Further, we, by way of the Internet Services, also capture such information that does not allow us to identify you either directly or indirectly; this is e.g. the case for aggregated information on all users of this Website.
When downloading the App, information is transmitted to the App Store. We are unable to influence this kind of collection of data and are not responsible for it. We will only process this data to the extent required for the downloading of the App onto your mobile device.
Further, you may access certain public parts of our Internet Service without providing us with your personal details (such as your name, postal address, or your email address). Also in this case, we need to collect and store certain information in order to enable your access to our Internet Service. On our Website and in our App, we use certain analysis tools and have integrated functionalities via third party providers. Further, we offer certain functionalities on our Internet Service for which we need to collect personal data.
We collect and process personal data on our Internet Service to the following extent:
Logfiles: If you visit our Website, our web server will automatically store data and information relating to the device and browser you use. This could include technical information such as browser, system type, and IP-address. We process this technical information in the logfiles of our systems. We process the technical information in order to enable your access to our Internet Service and to secure the functionality of our Internet Service and the security of our IT systems. The legal basis for this data processing is Art. 6 para. 1 lit. f GDPR (legitimate interest in making our Website operate efficiently). In some cases, we store data and information relating to the device and browser you use to optimize our Internet Service. In these instances, the legal basis for processing data is Art. 6 para. 1 lit. a GDPR (consent).
Registration and quote: Within the scope of our Internet Service, we offer you the option to register. This is necessary in order to obtain a cost calculation for the desired insurance coverage and an offer to conclude an insurance contract. For this, we request your name, email address, and further details about you and in connection with the risk to be insured. This is necessary in order to establish insurability or, as applicable, the level of potential insurance premium for you. The processing of this data is necessary in each case in order to prevent fraud, make the desired quote available to you for cost calculation and in order to be able to send you an appropriate offer by email, if necessary, with the provision of further information on the conclusion of an insurance contract. The processing therefore serves as preparation for entering into a possible insurance contract between us. Thus, the legal basis for the data collection and processing is Art. 6 para. 1 lit. b GDPR (contract performance). If you apply for an insurance contract via an intermediary party, we may also receive relevant personal data from such an intermediary party in connection to your application.
Application process: If you wish to accept the quote, you have the option to conclude the insurance contract with us directly online as further explained during the application procedure. In this context, you might, upon receipt of our legal offer, also transmit your payment details for the purpose of paying the insurance premiums due and accept our offer online and may ask for your phone number to contact you if needed in relation to your insurance policy. Following the conclusion of your insurance contract, you will be able to access further information on your account at any time – in particular in connection to the insurance taken out – and potentially include further information or, as applicable, ask to book add-ons to your insurance contract. We will subsequently send you the insurance policy by email. Thus, the legal basis for the data collection and processing is Art. 6 para. 1 lit. b GDPR and Art. 6 para 1 lit f GDPR (contract performance and legitimate interest in servicing your insurance policy).
Insurance contract including claims management: To access your account as well as regarding the administration of your insurance contract, e.g. for the purpose of invoicing or handling of claims, we may request entering data already given during the registration and/or application procedure once again (in particular for the purposes of identification). Furthermore, we will ask for additional personal information and supporting evidence of your claim to prevent fraudulent claims. You can submit your claim's details through the app or by contacting us. The legal basis for processing personal data in order to prevent fraudulent claims is our legitimate interest, Art. 6 para. 1 lit. f GDPR. The legal basis of conducting the insurance contract between you and us is Art. 6 para. 1 lit. b GDPR (contract performance).
Policy management: During the period in which your insurance policy is active with us, we might need to process policy changes, and for that, additional personal information might need to be collected. Thus, the legal basis for the data collection and processing is Art. 6 para. 1 lit. b GDPR (contract performance).
Contact after the registration process started: If you have already started to enter the details required for your quote, including your email address, but have not completed it, we may contact you to remind you to complete your application, provided you have consented to getting product updates and offers from us. The legal basis for this is either Art. 6 para. 1 lit. f (legitimate interest in assisting you with completing your application) or your consent according to Art. 6 para. 1 lit. a GDPR. You can always request to unsubscribe from further non-essential emails from us.
Contact support: You can also contact us through the contact form on the Website or by calling us. We collect all the data you provide and store it insofar as necessary to process your request. Calls may be recorded for quality and training purposes. If necessary, data will be stored longer after completion of processing for reasons of preservation of evidence. The legal basis is Art. 6 para. 1 lit. a, b, f GDPR (consent, contract performance and legitimate interest in responding to your inquiries and training our staff).
Fraud Prevention: In certain cases, we will store and process the personal data collected from interested parties even if no insurance contract is concluded. This is to detect and prevent fraud, attempted fraud, and/or other harmful and/or illegal activities. This serves to maintain our legitimate interests in the prevention of fraud, and illegal and harmful behavior. The legal basis is Art. 6 para. 1 lit. f GDPR.
Advertising information by email: If you have agreed to receive product updates and offers from us, we will process your email address, and potentially, information included in your account based on your corresponding consent, in order to be able to send you information with regard to our services, offers, and activities in the areas of household and liability insurance. You can always request to unsubscribe from further non-essential emails from us. Further, we might assess data collected during the delivery and retrieval of our emails for analytics purposes and to improve our communications. Your personal data in connection with an email subscription will not be disclosed to third parties for any purpose other than to allow us to technically send out communications and analyze the results of our communications through our technical providers. We will process your data exclusively for the selection of individualized content and for sending out product updates and offers within the scope of your consent granted. The legal basis is Art. 6 para. 1 lit. a GDPR.
Statistical evaluations: Where necessary, we assess your personal data for the purpose of evaluating your preferences to enable interest-orientated marketing, individual addressing, and a continuous optimization of our business processes in a statistical form. We do this in order to get a better understanding of what our customers expect from us. Further, these evaluations help us in the detection of fraud, and the revision and maintenance of security; we conduct this data processing in order to maintain our legitimate interests; the legal basis is Art. 6 para. 1 lit. f GDPR.
Social Plug-ins: On our Website, we use plug-ins of social network sites that allow you to conduct activities with regard to content on our Internet Service (also "Social Plug-Ins"). If you are registered in the respective social network and logged in to it, you may communicate directly with the social network. You may also prevent the loading of Social Plug-Ins with add-ons for your browser e.g. with the script blocker "NoScript" (http://noscript.net/). The legal basis for the provision of social plug-ins on our Internet Service is your consent Art. 6 para. 1 lit. a GDPR.
Referral program: Further, we might offer you the possibility to join a refer-a-friend program. You will receive a personal link which you send to your contacts. We will register which contacts have successfully used your link and any necessary information in order to perform the refer-a-friend program. The legal basis for this is therefore the performance of our agreement regarding the refer-a-friend program.
Further legitimate interests: Where required, we may process your data beyond the purposes mentioned above, for the purpose of maintaining our legitimate interests or for the interests of third parties; this is based on Art. 6 para. 1 lit. f GDPR. Some of our legitimate interests are
the assertion of legal claims and defence of legal disputes;
the prevention and the solving of crimes;
the steering and the further development of our business activities including risk management;
the prevention of fraud;
the ability to identify and resolve technical bugs in the system;
the ability to provide customer support (which is also based on the customer's consent pursuant to Art. 6 para. 1 lit. a GDPR); and the possible sharing of information as part of a corporate transaction or merger;
On our Website, we use short-term as well as permanent cookies. Some cookies are necessary for the functioning of our website and therefore cannot be disabled (‘Essential Cookies”). Other cookies are used by us for analytics and marketing purposes, and these will not be deployed unless you consent and opt-in through our cookie banner. Further information on online advertising cookies, and on how to prevent their use, can be found on the following websites:
- http://www.aboutads.info/choices/ (only available in English)
- http://www.networkadvertising.org/choices/ (only available in English)
Short-term cookies, such as, in particular, so-called ‘session cookies’ are deleted in an automated manner upon leaving our Website. These store a so-called ‘session ID’ by which different requests are allocated to the Website. By this, your device will be recognized when you use our Website again. The session cookies will be deleted when you log off or close your browser.
Permanent cookies will be deleted after a certain time in an automated manner, which may be different depending on the cookie. You may configure the settings of your operating system, to prevent e.g. the acceptance of third party cookies, or of all cookies.
In our app, we use different Software Development Kits ("SDKs") that provide us with data about your usage through our third parties providers. If you would like to avoid this data collection, you will need to close the app and use our Website instead. In any case you can always contact our customer service through the Website as an alternative to performing in app features.
Please note that if you have accessed other websites from the Lemonade Group operating outside of the EU or have agreed to accept cookies from this site in the past, you may have received cookies. If you wish to remove these cookies, please refer to the "manage cookies" section.
Advertising Networks: We may in particular use third party providers such as advertising networks and advertising exchange programs which enable us to include advertising for you on the sites of third parties. The operators of these external advertising networks and advertising exchange programs may, in the case of you consenting, use third party cookies, pixel or similar technologies in order to collect data (Art. 6 para. 1 lit. a GDPR). Where you consent, we will place cookies or a pixel on our own site in order to identify cases where a user gets to our Website through advertising placed on another website and completes certain activities (e.g. registration, or application for a quote or conclusion of a contract), for the purpose of remuneration of the advertising partner (Art. 6 para. 1 lit. a GDPR).
On our instruction, Google uses the transmitted data to evaluate your use of our internet presence, compile a report on the activities on the Website, as well as to render further services for us regarding the use of our Websites. (Therefore, there is a commissioned data processing agreement in place between us and Google). The use of Google Analytics therefore serves the purpose of continuously improving our internet presence and to optimise your user experience. These activities are in our legitimate interest regarding the data processing (Art. 6 para. 1 lit. f GDPR). Further, by clicking a button on our cookie banner on our Internet Service, you expressly agree to the processing of the collected data by Google in the manner, and for the purposes as described above (Art. 6 para. 1 lit. a GDPR).
If you wish to deactivate or change Google Analytics only in respect of the presentation of content tailored to your interests, including advertising, this can be adjusted under “Google adverts on the web” in the settings for Google Adverts.
Further information regarding the purpose and scope of the data collection as well as regarding the further processing and use by Google, including information on your rights or, as applicable, options for configuration for the protection of your personal data can be found under the following links: https://marketingplatform.google.com/about/analytics/terms/fr/ as well as under https://policies.google.com/privacy?hl=en-US.
Google Tag Manager: We also use Google Tag Manager. With this service, website tags can be administered via an interface. Google Tag Manager solely implements tags. This means that Google Tag Manager does not place any cookies and no personal data is collected. Google Tag Manager triggers other tags that potentially collect data, but Google Tag Manager does not access this data. If, at domain or browser level, a deactivation of certain websites is affected (see details on the deactivation of cookies given above), this remains in place for all tracking tags to the extent that these are implemented with Google Tag Manager.
Google AdWords / conversion tracking: On our Internet Service we also use, with your consent, (Art. 6 para. 1 lit. a GDPR) the online advertising program "Google AdWords,” and within the scope of this, its conversion tracking. With this, Google AdWords inserts a cookie or a pixel on your computer or, as applicable, on the storage of your mobile device, if you were directed to our Internet Service via a Google advert. These cookies are no longer applicable after 30 days. They do not serve for any personal identification. If the user visits certain pages of our Internet Service and the cookie is still active, both we as well as Google are able to see that you clicked on the advert and were forwarded to our site. We, as well as all other clients of Google-AdWords, receive different cookies. The cookies affected by our Google adverts can therefore not be followed beyond our Internet Service.
The information obtained from the conversion tracking serves to compile statistics on the conversion for us. With this, we learn about the total number of users who clicked on an advert and were forwarded to a site provided with a conversion tracking tag. However, we do not receive any information that would allow your potential identification.
If you do not wish to take part in conversion tracking, you may deactivate the conversion cookie in the settings of your browser. More information on this can be obtained from the Google Data Protection Statement.
You may also adjust your settings for Google Advertising in the Google settings for advertising.
Facebook Pixel:After gaining your consent (Art. 6 para 1 lit a GDPR), our Website has a re-marketing pixel from Facebook. Via this pixel, a direct connection to the servers of Facebook is provided during your visit to our Website. Through this, it is transmitted to the Facebook server that you have visited this Website and Facebook will assign this information to your personal Facebook user account. To protect your privacy, we do not use the so-called "extended alignment" function, in which this information could be enriched with further personal data (e.g. email address).
Mixpanel: We also use the web analytics service Mixpanel, in order to obtain data on the use of our Website for internal purposes, operated by Mixpanel, Inc., 405 Howard St, Floor 2, San Francisco, CA 94105, USA ("Mixpanel"). Mixpanel is obliged to maintain appropriate data protection levels. In the event of your consent (Art. 6 para. 1 lit. a GDPR), Mixpanel will insert a cookie on your device which also logs your user behaviour on the Website (retrieval of pages and activities on pages). This data is then analyzed by Mixpanel and forwarded to us.
Bing: On our Website pixels of the Bing Ads are implemented. Data is collected and stored from which anonymous usage profiles are created. This is a service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. This service enables us to track the activities of users on our Website when they arrive at our Website through ads from Bing Ads. If you enter our Website via such an ad, a pixel is placed on your computer and a Bing UET tag (Universal Event Tracking tag) is integrated into our Website. This is a code that is used in conjunction with the pixel to store some non-personal information about your use of the site.
These pixels are stored with your consent (Art. 6 para. 1 lit. a GDPR). The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. In addition, Microsoft may use so-called cross-device tracking to track your usage patterns across several of your electronic devices and is thus able to display personalised advertising on or in Microsoft websites and apps. Microsoft is obliged to maintain appropriate data protection levels.
Hotjar: We also use the analytics service Hotjar for internal purposes in order to provide a better experience to our customers and assist in diagnosing technical problems. The service is operated by Hotjar Ltd, St Julians Business Centre,3, Elia Zammit Street. St Julians STJ 1000, Malta, Europe.
This cookie is deployed with your consent (Art. 6 para 1 lit. a GDPR). You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
This cookie is deployed with your consent (Art. 6 para 1 lit. a GDPR). You may object to the use of AppsFlyer at any time and also with future effect by clicking here.
Alternatively, you will need to close the app and use our Website instead. In any case you can always contact our customer service through the Website as an alternative to performing in app features.
The details required for the conclusion of an insurance contract, as well as the registration for information by email, are in the respective areas of the Internet Service (e.g. in an online form) and marked as mandatory information; without providing the mandatory details, we are unable to allow you the use of the respective functionality.
Depending on the type of personal data that is processed by our company, only certain departments / organizational units have access to your personal data. These include, in particular, our expert departments concerned with the provision of our services and our IT department. Based on the concept of roles and entitlements, the access is, within our company, limited to those functionalities and such scope as is required for the respective purpose of processing.
We may also transfer your personal data within the legally-allowed scope to third parties outside of our company. These external recipients may include, in particular
affiliated companies (in particular Lemonade, Inc. in the USA and Lemonade Agency B.V. in the Netherlands), to which we transfer personal data for internal administrative purposes, management and servicing of our insurance product, data analytics, marketing, backoffice, the provision of hosting services and IT services required for the operation of this Website and Lemonade Agency B.V. for which we utilise the marketing and customer support services for the processing and execution of insurance contracts;
service providers instructed by us (including the sub-contractors of these service providers instructed with our consent), such as, e.g., in the areas of marketing, customer support, IT (in particular hosting or disaster recovery) and payment administration if they provide services to us on a specific contractual basis, which require the processing of personal data. Specifically, we utilize the payment services of the Hyperwallet group for outgoing payments and payment services of the Stripe group for incoming payments. The Hyperwallet group and the Stripe group have establishments outside the EU / EEA, in particular in the USA. You can find more information in regard to the processing of your personal data under https://www.hyperwallet.com/agreements-privacy/ and https://stripe.com/en-fr/privacy), as well as the sub-contractors of our service providers instructed with our consent or our affiliated companies;
non-public and public agencies to the extent that we have legal obligations to transmit your personal data;
reinsurance companies ("Reinsurers") that reinsure us. In order for our Reinsurers to be able to insure us, it may be necessary to provide our reinsurers with information relating to your insurance contract and your claims;
Companies that we partner with to conduct investigations and damages estimations during the claims process;
In order to provide you with a Amazon.fr voucher in the context of your participation in our refer-a-friend program or in the context of our marketing campaigns (where applicable), we provide Amazon.fr with your e-mail address and name. We do this to have Amazon.fr provide you with the voucher directly.
Other parties: we may share your information with other unaffiliated third parties who are not described elsewhere in this Policy with your consent.
We will transfer your data to external recipients only insofar as this processing is necessary for purposes as permitted by law.
We utilize automated decision-making in connection with the provision of our Internet Service. Automated decision-making, as defined in Article 22 of GDPR, may include profiling, which is any kind of automated processing that utilizes personal data in order to evaluate certain aspects of a natural person. The automated decision-making is based, in addition to other factors, on the information you provide during the quote process. We will use automated decision-making to evaluate the information you provide to us to calculate your individual risk profile in order to determine whether we can extend insurance coverage to you, and if so, what your insurance coverage limits and premiums will be, or to process claims you submit.
Under certain applicable laws, you may have the right to certain safeguards as they relate to automated decision-making. Specifically, you may be able to request that the result of the automated decision-making process is recalculated by a human, to express your views related to or contest the result of the automated decision-making process, and receive notification of the contestation outcome. In order to exercise these rights, or for more information about automated decision-making, please contact us at the information provided below. By applying for insurance, you acknowledge that you understand that automated decision-making or profiling may be used as described in this policy and you consent to Lemonade’s use of those methods.
In certain cases, there may be a transmission of information to recipients in so-called “Third Countries.” Third Countries are countries outside of the EU or the EEA, and it cannot automatically be assumed that their data protection levels are in line with those in the European Union.
In general, we will store your personal data only as long as we have a legitimate interest in this storage, and your interests in discontinuation do not overtake the legitimate interest.
Additionally, without any legitimate interest, we may continue to store your data where we are statutorily obliged to do so (e.g. for the purpose of fulfilling archiving requirements). We will delete your personal data without any action from your side, as soon as access to the data is no longer necessary to fulfil the purpose of processing, or the storage is otherwise illegal.
The personal data we need to store for the purpose of compliance with retention duties will be stored until the end of the corresponding retention period. Where we store personal data exclusively for the purpose of fulfilling archiving duties, it is normally blocked so that access is only possible where this is required with regard to the purpose of the retention duty.
Right to object according to Article 21 GDPR:
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, based on Article 6 para. 1 lit. e or f GDPR, including profiling according to Art. 22 GDPR based on those provisions. In the event of your objection, we will no longer process the personal data unless we have another permissible purpose for processing.
Where we process your personal data for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the concerned personal data shall no longer be processed for such purposes.
You have the possibility, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise your right to object by automated means using technical specifications.
Further rights of affected persons: Based on the following provisions, you as a data subject have the right:
to obtain access and information on your personal data which is processed, Art. 15 GDPR;
to have incorrect or incomplete personal data corrected, Art. 16 GDPR;
to request deletion of your personal data, Art 17 GDPR;
to request a restriction of the processing of your personal data, Art 18 GDPR; and
to data portability (this means that you have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and you may transmit your data to another controller), Art. 20 GDPR.
Further, you are entitled at any time to file a complaint with the responsible supervisory authority for data protection, Art. 77 GDPR. In France, the supervisory authority is the Commission nationale de l'informatique et des libertés.
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our Websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
Our services are not aimed at persons under the age of 16 years and their use is not intended for use by such persons. We do not collect personal data from people we know to be under the age of 16.