Sky Protect Privacy Notice

Introduction

This privacy notice applies to the processing of personal data that is controlled by Neos Ventures Limited, trading as Sky or Sky Protect (“Sky Protect”), in relation to our smart tech and home insurance business.

References to Sky refer to the parent company ‘Sky UK Limited’. If you are a customer of Sky in relation to any other product, including TV, broadband, mobile or NOW, you should refer to their respective privacy notices. If you are a customer who receives insurance for your devices or Sky equipment (e.g. the Sky TV box), historically known as Sky Protect but now ‘Sky Protect Gadgets’ or ‘Sky Protect Device Insurance’, please refer to the Sky and Domestic & General Insurance notices. If you were a customer of Neos Ventures Limited prior to them being bought by Sky, please see this notice for further details on how your data will be used going forward.

References to Comcast refer to the parent company of Sky, Comcast Corporation, 500 Gravers Road Suite 3000 Plymouth Meeting, PA 19462 United States.

This privacy policy will inform you as to how Sky Protect looks after your personal information when you purchase products & services from us, visit websites featuring our products or download apps as part of our products and services. It will also tell you about your privacy rights and how the law protects you.

If you access the products and services of other Sky companies and businesses, you should refer to their privacy notices.

Information we collect and how we use it:

Contact Details & Account Information

Contact details and other information on or about your account, including:

Name
Address
Contact information (such as phone numbers and email)
Date of birth
Sky iD
Payment information
Marketing preferences
Information about our products and services that you ordered or enquired about with us and with Sky, your interactions with us about those products and services, payment, offers, and cancellation history in respect of them

Contact Details & Account Information

From you, including through our websites, applications or when you access our services through other organisations, such as price comparison websites.

From you, including collected on call recordings or via live chat or our messaging services.

From other organisations, such as address verification services (e.g., Royal Mail), data brokers who supply us with contact information and credit reference agencies.

From Sky UK Limited and other companies within the Sky Group.

Contact Details & Account Information

To provide your service / perform our contract with you

to provide you with content, products, and services (including trials and offers), in accordance with the contract you have with us. This includes providing account management functionality, billing and payments, and other customer support.
to evaluate and fix problems with our products and services.
to pass your details onto the insurers, Zurich Insurance Company Ltd, AmTrust Europe Limited, and Inter Partner Assistance, who underwrite your insurance to allow them to enter into contract with you.
to check that you are using our products and services in accordance with the terms of the contract you have with us.

With your consent

to send or target you with direct marketing about our and Sky’s content, products, services events and special offers by post, telephone, SMS, email, notification or other electronic means to the contact details you have provided. In addition to the marketing that we send while you are a Sky Protect or Sky customer, we will also send marketing before you become a Sky customer, such as 'abandoned basket' marketing if you gave us consent to use your contact details for marketing during an online sales journey but didn't complete your purchase (we will tailor the marketing based on what you added to your basket) and for a reasonable time after you cease to be a customer of either Sky or Sky Protect.

Where we have a legitimate interest

to prevent and detect fraud, and protect or enforce our or any third party's rights. This may involve analysing activity on our network to help stop unauthorised access to content or publication of, or access to, unlawful content.
for market research.
to determine what offers you are eligible for in relation to our products and services and how to make these offers available to you.
to send or target you with marketing about our and Sky’s content, events, offers, products and services by post, telephone, SMS, email, notification or other electronic means, when you are a prospective customer.
to build a profile about you and your time as a Sky Protect customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
to confirm the personal data we hold about you (for example, your address).
to monitor, record, store and use customer service communications we have with you to help us to improve the quality of our customer service, to confirm any instructions you give us, to create a customer profile so we can have better conversations with you and/or to train or develop our staff.
to accurately record sales for accounting purposes and make commission payments.

Where we have a legal obligation

to comply with police and other security investigations
to enable Sky Protect to support customers whose circumstances might make them vulnerable, or in need of special assistance, including to comply with (and demonstrate compliance with) Ofcom's and the FCA's consumer protection requirements.
to store compliance records, including details of complaints received and records of insurance previously issued.

Where there is a vital interest

to safeguard your vital interests or those of another person to support crime prevention and protect the safety of members of the public and Sky employees.

Customer Service Interaction Data

This includes:

records of your customer service interactions with us, such as call recordings and records of your conversations and correspondence with us.
images recorded by cameras at Sky Retail Stores.

Customer Service Interaction Data

From you, when you contact us through any channel, including via phone and your image from CCTV footage recorded when you visit a Sky Retail Store or other Sky locations.

Customer Service Interaction Data

Where we have a legitimate interest

to monitor, record, store and use customer service communications we have with you. This helps us to: improve the quality of our customer service; confirm any instructions you give us; create a customer profile so we can have better conversations with you, and train and develop our staff.
for market research.
to help prevent and detect crime.
to protect the safety of Sky employees.

Where we have a legal obligation

to comply with police and other security investigations.
as part of supporting or defending legal claims (for example, where we need to disclose information as part of Court proceedings).

Where there is a vital interest

to safeguard your vital interests or those of another person to support crime prevention and protect the safety of members of the public and Sky employees.

Insurance Details

Contact details and other information provided for the insurance product, including:

Date of birth
Postcodes and data on a general area (such as flood risk, crime statistics, land registry information, geological survey, weather data)
Home ownership status
Type of insurance (such as contents, building etc.)
Tenure at address
Household composition
Number of and types of rooms in house
Date of cover
Indicators of criminal conviction or bankruptcy
Job title
Gender
Marital status
Payment details
Details of high value items
Claims data

Insurance Details

From you, including through our websites, applications or when you access or enquire about the services through applications on websites operated by other organisations, such as price comparison websites.

From insurers who underwrite your policy.

From other organisations, such as data brokers who supply us with information relating to housing and credit reference agencies.

Insurance Details

To provide your service / perform our contract with you

to provide you with quotes and renewal quotes for insurance and our products and services, prior to entering into a contract with you or in accordance with an existing contract you have with us. We will enrich the data you have provided to us with third party data sources to make an automated decision on your eligibility for insurance. Depending on the outcome of this, we may not be willing to insure you. Please see the section on Third Party Data below for more details on this including if you would like us to review discussions taken about you.
to pass your details onto the insurers, Zurich Insurance Company Ltd, AmTrust Europe Limited and Inter Partner Assistance, who underwrite your insurance product(s) to allow them to enter into a contract with you.

Where we have a legitimate interest

to carry out data analysis, including to ensure data accuracy and quality and for insurance risk modelling and product/pricing refinement. This is not to make decisions about you directly but, using this data as it relates to you, other customers, potential customers, and/or data provided by third parties (see below for the details we collect from Third Parties), to carry out insurance modelling and improve our processes, our products and services and check the way our models, algorithms and decision-making tools work.
to accurately record sales for accounting purposes and make commission payments.

Where we have a legal obligation

to store compliance records, including details of complaints received and records of insurance previously issued.
to comply with our obligations to the FCA and other regulators.

Audio/Video Recordings

Audio-visual recordings taken with the smart tech.
Live stream of audio-visual recordings viewed via the Sky Protect app.

Audio/Video Recordings

From you and your household when using Sky Protect products and services.

From the smart tech devices when they are configured to do so by you or another member of your household (e.g. to record when motion is detected in an area, or a doorbell is pressed).

From the smart tech devices when they are automatically triggered (e.g. by someone trying to tamper with the doorbell).

Audio/Video Recordings

To provide your service / perform our contract with you

to provide and administer products and services (including trials), in accordance with the contract you have with us.
to evaluate and fix problems with our products and services. This does not involve us accessing the actual audio/video recordings or live stream. If there is a reason why we need to do that in the future, we will notify you first.

Where we have a legal obligation

to comply with police and other security investigations.
as part of supporting or defending legal claims (for example, where we need to disclose information as part of Court proceedings).

Usage Data & Product Analytics

Information about how you or your household use, access, view, share, contribute to or otherwise interact with our smart tech devices and any associated apps, including:

Device ID
Records of devices being triggered, such as a doorbell press, motion sensors, auto-arming or a notification of status from a leak sensor.
Usage data on the Sky Protect app
Location data (to confirm whether you are inside or outside a geofence, when this setting is enabled by you in the Sky Protect app. If you decide to disable the geofence, we will not use this data.

Usage Data & Product Analytics

From you and your household when using Sky Protect products and services.

Usage Data & Product Analytics

To provide your service / perform our contract with you

to provide and administer products and services (including trials), in accordance with the contract you have with us.

Where we have a legitimate interest

to improve and develop new content, products, services and customer experiences.
for market research
to build a profile about you and your time as a Sky customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
to carry out data analysis, including insurance risk modelling and product/pricing refinement. This is not to make decisions about you directly but, using this data as it relates to you, other customers, potential customers, and/or data provided by third parties (see below for the details we collect from Third Parties), to allow us to carry out insurance modelling and improve our processes, products and services and check the way our models, algorithms and decision-making tools work.

Where we have a legal obligation

to comply with our obligations to the FCA and other regulators.
to comply with police and other security investigations.

Device Information & Telemetry Data

This includes:

technical information, including crash data, date of device installation, diagnostic data (such as errors and system statuses).

Device Information & Telemetry Data

From you and your household when using Sky Protect products and services, including the smart tech devices.

Device Information & Telemetry Data

To provide your service / perform our contract with you

to diagnose, evaluate and fix problems with our products and services.
to check that you are using our products and services in accordance with the terms of the contract you have with us.

Where we have a legitimate interest

to improve and develop new content, products, services and customer experiences.

Where we have a legal obligation

to comply with police and other security investigators.

IP Addresses & Online identifiers

This includes information from the devices you use to communicate with websites and applications on the internet, such as:

IP addresses
MAC addresses
unique identification numbers
online identifiers (for example, device IDs and advertising IDs)
browser information.

IP Addresses & Online identifiers

From the devices you use to communicate with websites and applications on the internet.

IP Addresses & Online identifiers

To provide your service / perform our contract with you

to provide you with content, products and services (including trails), in accordance with the contract you have with us.
to check that you are using our products and services in accordance with the terms of the contract you have with us.
to manage traffic across our networks and administer our products and services.

Where we have a legitimate interest

to determine the country you are located in so we can provide you with the correct information such as product and pricing information on our websites.
to enable us to accurately record sales for accounting purposes and make commission payments.
to prevent and detect fraud, and protect or enforce our or any third party's rights.
for online and digital advertising.
we will share your data with Sky (or they will collect it directly from the devices) to enable this. Sky will be a separate controller of your data for the marketing they carry out promoting Sky Protect. You can find out more about Sky's activities in relation to online and digital advertising in their privacy notice.

Where we have a legal obligation

to comply with police and other security investigations

Third Party Data

This includes information obtained from third parties, such as:

Contact information, including address
Data on a geographical area (e.g. flood data)
Modelled household profile information such as affluence and household composition
Personal data that is publicly available
Information held on you by credit reference agencies

Third Party Data

From other organisations, such as address verification services, data brokers, property and lifestyle agencies, and credit reference agencies, either directly or via Sky.

These organisations include:

Royal Mail
GoCompare
Experian
Equifax
Reed Group
TwentyCi
Ordnance Survey

If you want to manage how these organisations use your personal data and share it with companies like Sky and Sky Protect, you should get in touch with them directly. In the case of Experian, you can access their Consumer Information Portal here.

Third Party Data

To provide your service / perform our contract with you

to provide you with quotes and renewal quotes for insurance and our products and services, prior to entering into a contract with you or in accordance with an existing contract you have with us. We enrich the insurance details you have provided to us with third party data sources to make an automated decision on your eligibility for insurance. Depending on the outcome of this, we may not be willing to insure you. If you would like us to review decisions taken about you, please contact us via one of the methods in the Keeping your data up to date and your rights section below.

Where we have a legitimate interest

to assess your suitability for our insurance offering.
to send you direct marketing where we’re not relying on your consent to do so, for example, if you’re a prospective customer.
to verify the personal data we hold about you is accurate (for example, your address or identity).
to build a profile about you and your time as a Sky Protect customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
for online and digital advertising. We will share this with Sky (or they will receive it directly from the third parties) to enable this. Sky will be a separate controller of your data for the marketing they carry out promoting Sky Protect. You can find out more about Sky's activities in relation to online and digital advertising in their privacy notice.

Where we have a legal obligation

to prevent fraud and money laundering

Legacy Neos Data
This includes information from legacy customers of Neos Ventures Limited, prior to the company trading as Sky Protect, including:

contact details & account information
records of insurance
audio/video recordings
usage data and product analytics
device information and telemetry data
IP addresses & online identifiers

Legacy Neos Data

From you, including through the Neos website, applications, and smart tech.

Legacy Neos Data

To provide your service / perform our contract with you

to provide you with content, products, and services, in accordance with the contract you have with us.
to evaluate and fix problems with our products and services

With your consent

to send or target you with direct marketing about our content, products, services, events, and special offers by post, telephone, SMS, email, notification, or other electronic means to the contact details you have provided. We will also send marketing for a reasonable time after you cease to be a customer of Neos Ventures Limited.

Where we have a legitimate interest

to improve and develop new content, products, services and customer experiences for Sky Protect products.
to carry out data analysis, including insurance risk modelling and product/pricing refinement. This is not to make decisions about you directly but, using this data along with that of other customers, potential customers and in combination with data provided by third parties (see above for the details we collect from Third Parties), to carry out insurance modelling and improve our processes, products and services and check the way our models, algorithms and decision-making tools work.

Where we have a legal obligation

to store compliance records, including details of complaints received and records of insurance previously issued.
to comply with police and other security investigations.

How we share your information

In order to provide our services, we work with a number of suppliers and partners with whom we share your personal data. We grant these companies access to personal data only where necessary and only where appropriate security measures and controls are in place to protect your personal data. When these companies act on our behalf, they will only process your personal data in accordance with our instructions and for the reasons set out in this notice.

We have set out below the categories of suppliers and partners that we work with and why we share your personal data with them.

Our Suppliers & Partners	When and why we share your personal data with them…
Insurance providers	We will share your contact details, account information, insurance details and any other information required to allow our partners to underwrite the Sky Protect insurance products, such as Zurich Insurance Company Ltd, AmTrust Europe Limited and Inter-Partner Assistance.
Couriers	We will pass on contact details to deliver packages or other postal documents to you on behalf of Sky Protect. Couriers may also process your contact details as a data controller when arranging or communicating with you about your delivery.
Payment service providers	We will share financial details and any required associated information to process payments in relation to our services.
Price Comparison Websites	We will share your contact detail, account information, some insurance details (please see the section above on Information we collect and how we use it for more detail), and information about how you made your purchase with price comparisons websites, such as Compare the Market, GoCompare, MoneySupermarket.com or Confused.com when you have used their services to review insurance options and gone on to make a purchase with Sky Protect. This it to enable us to accurately record sales for accounting purposes and make commission payments. You should refer to the price comparison website’s own privacy notice for more details about what information they share and how to manage your preferences.
IT and information technology and services companies	We will share personal data as part of providing the secure Sky and Sky Protect IT infrastructure where your personal data is stored and processed. Occasionally, we share limited data about you with third party service providers that are necessary for you to enjoy the smart tech, such a cloud service providers and manufacturers of the hardware or software of the smart tech. This allows us to identify and resolve technical issues impacting the delivery of our services to you so you can continue to receive uninterrupted Sky Protect services.
Customer service centres, including those operated by third parties for Sky and Sky Protect	We will provide access to your Sky Protect account information to the customer agent when you ring us for assistance.
Sky UK Limited and other Sky Group companies or companies in the Comcast group	We share personal data with Sky acting as our processor in relation to the development, operation, infrastructure and performance of our products and services. We will also share data with them on a controller-to-controller basis for corporate reporting, data analysis, marketing, online and digital advertising, and to allow the application of offers and discounts to Sky customers who also decide to become customers of Sky Protect (and vice versa). If the structure of our business changes so that another company in the Sky group provides our products and services to you, we will pass your personal information to that company. This includes, for example, a merger between us and another company, where another company acquires us or some or all of our assets, where we acquire another company or where Comcast restructures our corporate group.
Credit reference agencies (e.g, Equifax, Experian and/or CRIF) and fraud prevention agencies (e.g. CIFAS)	When you apply for a quote or a renewal, either directly with us or through a third-party website, such as a price comparison website, we will run a credit check on you by passing your contact information to a credit reference agency to assess your suitability for our insurance products, confirm your identity and prevent or detect fraud and money laundering, as further explained below. Where we carry out a credit check with a credit reference agency, the information that we give them and the details of the search itself will be recorded by that credit reference agency but the search will not be visible to potential future lenders to use when assessing your ability to obtain credit. As part of your credit check, the credit reference agency may also review information in relation to individuals who are financially linked to the primary policy holder. If you are making an application for a joint insurance policy or inform us that you are married or in a civil partnership, the records will be linked together so you must be sure that you have their agreement to disclose information about them. Credit reference agencies also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the credit reference agencies to breach that link. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you. Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place. Where appropriate, we may also share your data with other organisations to assist with the prevention and detection of fraud.
Data Brokers	We share your contact details, account information and insurance details with brokers for marketing and analysis. This includes Experian who we use to match Sky’s own data with their own data set to confirm data provided by individuals – this data matching process enables us to provide an accurate quote on your property.
Marketing companies	We pass contact details and account information onto agencies who require this information to create and deliver our communications.
Courts, enforcement agencies (e.g. the police) and with regulatory authorities	If required for us to comply with our legal and regulatory obligations, we will share personal data with official bodies.
Other nominated individuals	When Sky Protect receives a request for the ownership of a vulnerable customer’s account to be transferred to a nominated individual, personal data of the existing account holder may be shared with the new account holder. The ownership of the account would only be transferred once Sky has received signed acceptance and authorisation of the transfer from both parties.

Sometimes we share personal data with suppliers and business partners who may process it outside of the UK (for example, we use some IT services in EU and USA). We grant these companies access to personal data only where necessary and only where appropriate security measures and controls are in place to protect your personal data in accordance with applicable data protection laws, regulations and regulatory guidance. This means these transfers will take place based on an approved data transfer mechanisms, such as relying on adequacy decisions from the UK government or using the appropriate standard contractual clauses in our contracts with our suppliers and business partners.

Contacting Sky Protect

If you have any queries or comments about this privacy notice, please write to: Sky Protect, Firstsource Solutions Ltd, Orbis Business Park, Riverside Road, Pride Park, Derby, DE24 8HY. Or contact Sky Protect's Data Protection officer via: dp.department@sky.uk

Changes to this notice

We will occasionally update our privacy notice. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using any of the contact details we hold for you for this purpose. This may include phone, SMS, e-mail, post or interactive social media. We encourage you to periodically review our notice to be informed of how we use your information.

This privacy notice was last updated 06 January 2023.