(Effective February 1, 2022)
Before we get started, here are a few terms we think you should know as you read this Policy.
“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy in the place where you live. This includes: (1) the “GDPR” , the European data protection law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; (2) “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada; (3) the California Consumer Privacy Act (“CCPA”) which applies to our activities in the United States in certain circumstances; and (4) the “UK GDPR” which applies to our activities in the United Kingdom; please note that when this Policy refers only to the “GDPR”, this includes the UK GDPR as applicable. Slice is committed to adhering to all these applicable Data Protection laws.
“Personal data” – this is information we collect from you or about you and which is defined in the GDPR as “any information relating to an identified or identifiable natural person.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Under PIPEDA and the CCPA, the equivalent concept is “personal information”, which is roughly the same. Any mention of “personal data” in this Policy shall also mean personal information.
Slice is actually three different but related companies who are owned by the same people - in the U.K. (Slice Labs UK Limited), the U.S. (Slice Insurance Technologies Inc.) and Canada (Slice Labs Inc.). All of those companies are committed to protecting your privacy and conforming to the Data Protection Laws applicable to you.
Under the GDPR, Slice is a “Data Controller”. That means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy and other documents linked to from this Policy in that way.
If you want to ask us anything about what’s in this Policy, or anything else privacy or data related, you can email firstname.lastname@example.org. Here are our mailing addresses for you as well:
Slice Labs UK
5 New Street Square, London, EC4A 3TW United Kingdom
Slice Insurance Technologies Inc.
33 Irving Place, Suite 7116, New York, NY 10003 USA
Slice Labs Inc.
14 Chamberlain Avenue, Ottawa, ON K1S 3T3 Canada
In addition to the contact information above Slice has designated a Data Protection Officer (DPO) who is responsible for all personal data matters at Slice. If you have a specific complaint or wish to invoke your legal rights under any Data Protection Law, please contact our DPO directly:
1-866-667-5423 (toll-free) in North America
0330 808 5583 in Europe or the United Kingdom
You have the following rights regarding your personal data held by Slice, and other rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. These rights may be exercised without affecting the price you pay for any of the Services.
If you wish to exercise any of these rights, please contact our DPO at the contact information above.
In the table below, please find all the personal data we may collect from you directly, what we use it for, and the legal basis under the GDPR for us having and processing this personal data. Under PIPEDA, the legal basis is your informed consent, and by submitting this personal data you acknowledge having granted this consent to Slice.
|Personal data category||Personal data processed||What we use it for (the “purpose” of processing)||Legal basis for processing under the GDPR|
|Contact information||Your first name, last name, company name and email address||To communicate with you||Your consent in giving us this information|
|Employment application information*||Your name, your email address, your phone number, your mailing address, and any personal data in your cover letter or CV||To find out if you are a good fit to work with Slice!||Your consent in giving us this information|
|Account information||Name, email address, mailing address, and address of any properties or businesses you wish to insure||To create an account for you, to communicate with you, and to sell you insurance||Your consent and performance of a contract between you and us|
|Insurance information||Details about what you want to insure, whether the property you are renting, your car, your business, etc.||To sell you insurance and determine what that insurance should cost||Your consent or performance of a contract between you and us|
|Billing information||Credit card holder name, number, expiration date, CVV number and billing address||To allow you to pay for the insurance you want to purchase||Performance of a contract between you and us|
|Claims information||Any personal data included in pictures or other documents sent to us when making a claim under your insurance||To determine if your claim is warranted, and if so, the amount to be paid to you||Performance of a contract between you and us|
*Your employment application information is collected via the third-party service BambooHR; once received by Slice from BambooHR it will be treated in accordance with this Policy.
Where you have provided personal data further to the contract between you and us, if you fail to provide such data or withdraw your consent to use such data, we will no longer be able to sell you insurance or process your claim.
Sometimes we get personal data about you from third parties. This table explains the details about this personal data – what it is, where it came from, what we do with it, and the legal basis for us having and processing this personal data under the GDPR. Under PIPEDA, the legal basis is your informed consent. None of this data comes from publicly-available sources.
|Personal data category||Personal data processed||Who we get the data from||What we use it for (the “purpose” of processing)||Legal basis for processing under the GDPR|
|Insurance information||Details about what is to be insured, for example your property or your business||A third party you have authorized to buy insurance on your behalf||To provide you with insurance||Performance of a contract between you and us|
|Claims information||Any personal data about you such as your name and contact information||A Slice user who submits information about you when they make a claim||To determine if the user’s claim is warranted, and if so, the amount to be paid||Your consent given to the Slice user|
We routinely share some of your personal data with certain types of third parties who are identified in the table below along with what they do with it. Some of those third-party recipients may be based outside your home jurisdiction. If you are in the European Economic Area or the United Kingdom— please see the “Transfer of Your Personal Data Outside of the European Economic Area” further down in this Policy for more information including on how we safeguard your personal data when this occurs.
We will never share your personal data with other third parties except under these circumstances. We do not sell your personal data to any third party for direct marketing purposes or any other purpose.
|Personal data category||Who we transfer it to||What they do with it|
|Contact information||Send you emails or SMS messages; store it so that we may retrieve it to contact you|
|Account information (including contact information)||Underwrite your insurance, communicate with you about insurance, various needs to sell you insurance, and record-keeping|
|Insurance information||Various tasks in selling you insurance including validating information you submit and record-keeping|
|Billing information||Payment processing companies, particularly Stripe||Process your payments for insurance you buy|
|Claims information||Companies that process claims||Process and determine the value of your claim|
|Advertising identifiers||Companies that provide ad networks, like Google||Show you ads for Slice when you are on the internet|
|Analytics identifiers||Companies that provide data analytics||Provide us with analytics as to how the services are used, and to trace fraudulent activities|
We have implemented very strict technical and organisational procedures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost; or used or accessed in any unauthorised way.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.
When you buy insurance through Slice, your personal data is transferred with encryption using Transport Layer Security (“TLS”), the highest security standard for Internet transactions.
For our European users, we endeavour to keep your personal data inside the EEA or the U.K. (as applicable). However, certain of our data processors (and some of Slice!) are in other countries where your personal data may be transferred. However, these countries are limited to countries with particular circumstances that protect your data, specifically:
That’s it! You have the right, however, to refuse to have your data transferred outside the EEA or the U.K. Please contact our DPO to make that request. Please note that making this request may prevent you from being able to use a portion or all of the Services.
If you are in the EEA or the U.K., under the GDPR you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our DPO, or if you would like to make a complaint directly about Slice’s data practices, we invite you to contact the supervisory authority in your country. If you are in the U.K., you should contact the Information Commissioner’s Office who is the supervisory authority. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF).
The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA can be found here.
In addition to the European Data Protection Authorities, Slice is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If you are in California and you are not satisfied with the response received or the actions taken by our Privacy Officer, you can make a complaint to the California Attorney General, via their website.
Finally, if you are in Canada and you are not satisfied with the response received or the actions taken by our DPO, you can make a complaint to the Office of the Privacy Commissioner of Canada. Instructions on how to do so can be found on their website.
Your personal data will only be kept for as long as it is necessary for the purpose needed for that processing. For example, we will retain your account information for as long as you need to have an account with us.
Because insurance is a heavily regulated industry, sometimes we have to keep your data for a longer period of time to satisfy our requirements under the law, so we may retain your personal data for a longer time based on this factor.
Slice uses certain automated decision-making processes, taking some of your personal data, especially insurance information, to determine the cost of the insurance you purchase through the Services.
The Services are not intended for children under the age of 13. We do not knowingly collect any personal data from a child under 13. If we become aware that we have inadvertently received personal data from a person under the age of 13 through the Services, we will delete such information from our records.
The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy, and we will update it no less than once every 12 months. You can always find the most updated version at this URL, and we will always post a notice on our website if we make big changes. If you have a Slice account, we will also email you to tell you the Policy has been updated, and what the important changes are.
© Slice Insurance Technologies Inc. 2022