Your privacy is important to us, and this policy sets out what we will do with your personal information.
WHAT INFORMATION WE COLLECT
We collect your information and use it in different ways depending on your relationship with us and how you have interacted with us. This can include information we share with or receive from other third parties.
We use your information for the following lawful reasons:
To enter into or perform a contract: for example, to provide a travel insurance quotation, to arrange and administer your insurance.
This information may also include sensitive (special category) data such as your medical history and conditions, which we can collect on the grounds of substantial public interests to provide you with a quotation and/or arrange your insurance. This applies whether you are providing your information via our call centre, our website or via the online self-serve members area.
To comply with a legal obligation: for example, the rules set by our regulators the Financial Conduct Authority (FCA), The Gibraltar Financial Services Commission (GFSC) and also The Financial Ombudsman Service, to fulfil your data rights under data privacy laws, handle complaints about data privacy or our insurance products and services and to comply with other legal requirements
For yours and our legitimate interests: for example, to detect and prevent fraud, money laundering and other financial crimes, monitor and improve our business, products and services, demonstrate compliance with applicable laws and regulations, handle legal claims, respond to other types of complaint not previously mentioned, and sending you postal direct marketing activities.
With your consent: for example, sending you email marketing communications about our own products and services and those from trusted third parties. You can withdraw your consent at any time.
To protect vital interests: in extreme or unusual circumstances, we may need to use your information to protect your life or the lives of others.
WHEN WE COLLECT INFORMATION ABOUT YOU
We collect information about you to provide an estimate or quote, facilitate the purchase of products through this site and to carry out our obligations for any agreement you have with us (and information relating to joint, family or group applications). We also collect information when you contact us to request information, visit our website, apply for a policy, renew a policy, claim under a policy, respond to a customer survey, questionnaire or marketing campaign.
We will use your personal information, and may share your personal information with other third parties acting on our behalf, for one or more of the following purposes:
- provide the services you have requested.
- work out financial and insurance risks by credit scoring.
- understand our customers’ needs and requirements.
- carry out research and analysis about our products and services.
- provide tailored information and offers about other products and services that may be of interest to you (where you have provided your consent).
- carry out our obligations for any agreement you have with us.
- recover debt.
- for any regulatory or legal purposes imposed on us (for instance for reporting to the Financial Conduct Authority); and
- any other legitimate interest of ours such as for carrying out credit checks, preventing fraud, maintaining adequate records or for the recovery of unpaid debts.
We may contact you by phone or post and, if you provide us with an email address or mobile phone number, we may send you emails and/or text message with operational messages about your insurance policy. As texts and emails are not necessarily secure and can be intercepted, we will keep confidential information to a minimum.
WHAT INFORMATION WE USE AND HOLD ABOUT YOU
Depending on your relationship with us, we may hold the following types of information about you:
- Identity and contact information: for example, your name, date of birth, postal address, telephone number and e-mail address.
- Payment and bank account information
- Correspondence data: for example, copies of letters and e-mails we send you or you send to us, and notes or call recordings of any telephone conversations.
- Internet data: for example, information collected by cookies and other online technologies such as Facebook pixels and Google Analytics
- Information we obtain from other sources: including credit agencies, anti-fraud and other financial crime prevention agencies and other data providers.
- Complaint data: for example, what the complaint was, how we investigated it and how we resolved it.
- Information disclosed to the insurers of the policy and their assistance and claims handlers.
We may use your information to:
- Keep you informed by email, post, telephone, SMS, or other communication means about products and services, articles or competitions that we believe will be of interest to you.
- Personalise your customer journey to improve your experience.
- Carry out market research or data analysis to help us improve the services we provide or to design new services for the future.
If you do choose to stop receiving marketing communications from us, we will ensure that you do not receive such material going forward, unless you change your mind and specifically request it in the future.
We may contact you if you abandon or fail to complete an online quotation or application to see if we can offer you any assistance.
We may also display tailored online advertising on third party websites, such as social media sites, sites operated by internet service providers and sites which sell advertising space.
We may use the information that we hold about you to personalise the advertisements to you. Where we display personalised advertisements on third party sites, we display the Ad Choices logo which you can click on for further information about online behavioural advertising.
You can opt out of marketing during the application process or at any time by using the unsubscribe options when we contact you, via your customer area, or by calling us.
AUTOMATED DECISION MAKING AND PROFILING
Our on line system carries out automatic decision making and profiling to decide whether we can provide insurance to you and at what price and on what terms. If you do not want your data processed by these automated means, then you can contact us by phone.
WHO WE MAY SHARE YOUR DATA WITH
Where applicable, some or all of the information you supply to us in connection with your insurance proposal may be passed to third parties including:
- Insurance, underwriters and other companies for arranging and administering your insurance, and for handling claims and premium collection purposes.
- service providers (such as our marketing partners that we may conduct marketing activities through).
- credit reference agencies.
- other sub-contractors who may assist us in providing the services requested from you.
- A third party where disclosure is required to comply with legal or regulatory requirement.
- A third party we may choose to sell transfer or merge our business with; and
If you apply to us for insurance, we will also pass your details to the insurer. Information provided by you may be put onto a register of claims and shared with other insurers to prevent fraudulent claims.
TRANSFERRING DATA INTERNATIONALLY
Wherever possible we will not transfer your information to countries outside of the European Economic Area (EEA). Where we do transfer your information outside of the EEA, we shall put in place suitable safeguards to ensure the protection of your information.
Please refer to the cookies policy.
FIND OUT MORE OR REQUEST A COPY OF THE INFORMATION WE HOLD
You can find out more about how we use your information by simply calling us or writing to us:
Write to us: The Data Protection Officer, Starpeak Insurance Solutions Limited, Dovetail House, Wycombe Road, Stokenchurch, Bucks, HP14 3RQ.
YOUR DATA PROTECTION RIGHTS
Data protection law gives you rights relating to your personal information. Set out below is an overview of these rights and how they relate to the information you give us.
The UK supervisory authority for data rights, the Information Commissioner’s Office (ICO), has also published detailed information about your rights on their website: www.ico.org.uk.
Right to access
You have a right to request copies of the personal information we hold on you, along with meaningful information on how it is used and who we share it with.
Right to rectification
If information we hold is inaccurate or incomplete, you have the right to have any inaccuracies corrected and for any incomplete data to be completed.
Right to erasure (the right to “be forgotten”)
You have the right to request that your personal information is erased.
Right to restrict processing
You can ask us to restrict the use of your information.
Right to object to direct marketing
You can object to receiving direct marketing from us.
Your right to object to automated decision-making
You can object to decisions made about you using your information and undertaken by purely automated means.
Right to object to processing
Right to object to the use of your information for statistical purposes
You can object to us using your information for statistical purposes in some instances.
Right to data portability
You have the right to request that your information be compiled into a common, machine-readable format and either provided directly to you or sent by us to a third-party you nominate.
Right to complain
If you have a complaint about how we use your personal information, please contact us by email at firstname.lastname@example.org
Or by post:
If you remain unhappy with our response, you may raise a complaint with a supervisory authority responsible for data protection and privacy.
In the UK, the supervisory authority is the Information Commissioner’s Office (ICO), which can be contacted using the following details:
By e-mail: email@example.com
By telephone: 0303 123 1113
The Information Commissioner’s Office
We will only retain data for as long is necessary for the purposes for which it is being processed and in line with our data retention policy. In most cases, this will be a maximum of 7 years from the expiry of an insurance contract.
LINKED WEBSITES AND INFO SECURITY
We are committed to protecting the online privacy of visitors to our website. We have implemented security policies, rules and technical measures to protect your personal data from unauthorised access; improper use or disclosure; unauthorised modification; and unlawful destruction or accidental loss.
If you contact us by email, you should be aware that emails are not secure unless they have been encrypted. Please consider this before emailing personal or confidential information to us. We cannot accept any responsibility for the unauthorised access to your data that is beyond our control.
UPDATES TO THIS POLICY