Privacy Policy – Spectrum Travel Insurance

Last updated January 2020

Spectrum Travel Insurance are committed to protecting your privacy when dealing with your personal information. This privacy notice provides details about the information we collect about you, how we use it and how we protect it. It also provides information about your rights and choices that you have over your personal information. It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.

Who we are

Spectrum Travel Insurance is a trading name of Travel Insurance Facilities Plc which is authorised and regulated by the Financial Conduct Authority, Travel Insurance Facilities Plc (tifgroup) is a Managing General Agent (MGA) which provides full lifecycle travel insurance and undewrites policies on behalf of the insurer: https://www.spectrumtravelinsurance.co.uk/our-insurers.

This privacy policy explains how we control and process any personal information we collect or you provide about you when you use our website, obtain a quote, buy a policy, subscribe to our newsletter, interact with us via social media, email or call us by phone.

Important information about us as the Data Controller

Travel Insurance Facilities Plc is registered as a data controller with the Office of the Information Commissioner (ICO), registration number Z5712152 and is responsible for controlling the use of your data in relation to your insurance policy with Spectrum Travel Insurance.

As a data controller, we need to collect and process relevant personal information, including sensitive data such as your answers to medical questions, which you give us when you use our services either online or over the telephone. The provision of our services may also require us to store details of your transactions, together with all declared personal information. We do not store any data relating to your debit/credit cards.

With your information, we will provide you with a quotation and/or administer your insurance policy. For this reason, your data may be shared with other parties, including the insurers, for the purpose or arranging insurance.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights detailed below, please contact the DPO using the contact details below.

Contact details:

Data Protection Officer

Travel Insurance Facilities PLC
Postal address: 1 Tower View, Kings Hill, West Malling, Kent, ME19 4UY

Email address: dpo@tifgroup.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

We may change this page from time to time, to reflect how we are processing your data. If we make significant changes, we will make that clear on our website. This version of the privacy policy was last updated in January 2020 and historic Privacy Notices’ are archived and can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and updated. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

We use Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details. Financial data will be encrypted accordingly and not stored.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Health and Medical Information includes medical history obtained from you, GP records (with your express consent), medical reports from hospitals abroad and other medical information required to fulfil our obligation as your travel insurer.

If you fail to provide data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or, are trying to enter into with you, for example, to provide you with travel insurance.

How is your personal data collected?

We use different methods to collect data from and about you including through direct interactions. You may give us your Identity, Contact and Financial Data by purchasing travel insurance products either through our contact centre or through our website, including correspondence with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:

Create an account on our websites;
Subscribe to our service or publications;
Request marketing to be sent to you;
Enter a competition, promotion or survey;
Give us some feedback.
Automated technologies or interactions – As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources – We may receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

Analytics providers such as Google based outside the EU.
Advertising networks such as Affiliates based in the UK.
Search information providers
Identity and Contact Data from data brokers or aggregators within the EU.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How we use your personal data

Before you provide any data to us, we will endeavour to make it clear why we need it. We will only use your personal data when the law allows us to:

Where it is necessary for us to perform the contract of insurance.
Where it is necessary for our legitimate interest and in circumstances, we underwrite the policies, we may send data or reports to the insurers.
Consent: In certain circumstances, we may need your consent unless authorised by law in order to use personal information about you which is classed as “special categories of personal data”.
Necessity to establish, exercise or defend legal claim: If you, or we, bring a legal claim (e.g. a court action) against the other, we may use your information in either establishing our position, or defending ourselves in relation to that legal claim.
Where we need to perform our obligations within your contract accounts will provide refunds, reports and answers to payment queries.
Where we arrange and administer your policy
Where third parties use our system to conduct a medical declaration and, in these circumstances, the third party will be the data controller.
Where third parties use our claim system to process their customer’s claims. In these circumstances, the third party will be the data controller.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

Purpose	Type of data	Lawful basis for processing including basis of legitimate interest
To send reports to the Insurers of incidents that the Insurers need to be aware of.	Identity Health and Medical Information	Necessary for our legitimate interests (to pursue assistance from insurers)
To provide a refund or if you have paid an excessive amount than necessary	Identity Contact Financial	Consent Our legal and Regulatory obligations
Available vacancies on tifgroup website for you to apply and submit your CV.	Identity Contact	Consent
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	) Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To collect and recover money that is owed to us	identity Health and medical information	Necessary for our legitimate interests in recovering money that is owed to us.
To use the personal data of new customers for marketing other products or services (where you’ve opted in)	Identity details Contact details	Consent from you to be able to contact you about our products and discounts that may be of interest to you. Necessary for our business legitimate interests
To use the personal data of existing customers for marketing similar products and services (where you haven’t opted out)	Identity details Contact details	Consent from you to be able to contact you about our products and discounts that may be of interest to you. Necessary for our business legitimate interests
To collect and process your personal data through cookies to optimise your customer experience, to develop new ways to meet our customers’ need, to grow our business and to identify and prevent fraud	Technical Usage	Necessary for our legitimate interests to optimise your customer experience and for us to develop new ways to meet customer’s needs. To help grow our business and to identify and prevent fraud.
To report data (including personal data) to government organisations e.g. Police, regulators, Courts	Identity details Contact details	Legal Obligation
To help identify, prevent, investigate and report potential fraud	Identity details Contact details Health/Medical information Financial information	Compliance with a legal obligation to report fraud and our legitimate interests to investigate suspected fraud and share data with fraud prevention agencies.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly in marketing and advertising. We have established methods to provide you with an option to make a decision whether you would like to receive marketing materials. If you would like us to stop sending certain, or any marketing materials you may opt-out by contacting us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have:

Requested information from us
Purchased an insurance product
Provided us with your details when you entered a competition or,
Registered for a promotion

In each case, you have not opted out of receiving these communications from us.

Third-party marketing

We will get your explicit opt-in consent before we share your personal data with any company other than us for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase as we may still need to contact you as part of your contract of insurance.

Cookies

You can set your browser to refuse all, or some browser cookies or to alert you when websites set, or access cookies. If you disable, or refuse cookies, please note that some parts of this website may become inaccessible, or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal information

We will not knowingly disclose or pass on your personal data to anyone else except:

when carried out in conjunction with our normal insurance operations and the administration of your insurance policy, such as to Insurers, claims handlers or emergency assistance companies; and/or
as authorised by you; and/or
as provided for in the Marketing section below; and/or
as permitted or required by law to any regulator, auditor, public office, authorised monitor, governmental or law enforcement agency (such as for the purposes of fraud prevention).

Where data is passed to other companies, it is anonymised, if appropriate, and it is done so on the understanding that they will maintain compliance with the appropriate data security provisions, particularly where such companies are located outside of the European Economic Area (EEA).

Transfer of data outside of the EEA

We may transfer personal data to, and process personal data in a country outside of the European Economic Area (EEA) other than with our branch based in Mumbai. If we do transfer your data outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. In most cases, this will be by using approved EU approved contractual clauses. We may also process your data in countries which have reached Adequacy Decisions with the European Commission, or are part of the Privacy Shield in the US.

Whenever fraud prevention agencies transfer your personal data outside of the EEA, they too will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. They also require the recipient to subscribe to ‘international frameworks’ intended to allow secure data sharing.

We provide a seven-day a week service to our customer and clients through our legally established and registered Branch in Mumbai, India. To the extent that our Branch receives phone calls and email communications from our UK and EEA based callers, it is deemed to be a data processor. All servicing is done by a secure connection to our servers based in the UK. No data or voice recordings are held locally. There is a strict entry/exit procedure on the customer services floor with electronic passes. Employees in customer services are not allowed to make any notes on paper or carry any recording devices, such as mobile phones, in the work area.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Transaction security

We utilise appropriate security systems to protect all financial transactions carried out on our website. Information, such as credit card details, is automatically protected using a Secure Socket Layer (SSL) between your computer and ours which prevents impersonation. (Click on the padlock symbol at the bottom of the screen to reveal a registration certificate issued by a leading internet security company for us and/or the payment handling company). SSL also encrypts data from the time it leaves your computer until it reaches us, so there is almost no chance of your details being stolen or hijacked as it travels over the internet.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Automated Decision Making & Profiling

Automated decision-making is the making of a decision about you based solely on automated means without any human involvement. This occurs when we conduct a medical screening at the beginning of your customer journey either online or through our call centre. The system is pre-programmed algorithms that assist in calculating your premiums.

You have the right to object to profiling and automated decision-making as set out below. In these circumstances, you have the right to request an adviser of ours to review the automated decision, as part of this process you also have the option to let us know the reason for your objection and ask us for a reconsideration of the decision. You can contact us to exercise these rights.

By law, we must tell you when we rely on an automated decision-making process, (making a decision using technology, without any person being involved). This occurs when we conduct a medical screening at the beginning of your customer journey either online or through our call centre.

The system is pre-programmed algorithms that assist in calculating your premiums. We are also required to tell you when we use profiling (automated processing of your information to help us evaluate certain things about you, for example, your personal preferences and your interests) for example:

Underwriters: our underwriters will assess risk, calculating premiums and what kind of cover we can offer. The type of data we will process are Identity Data and information about your trip for us to understand the likelihood of a certain event that may occur. With the results, we will determine the premiums and extent of cover.

Medical screening: we use a risk rating tool which determines the answers given to the relevant questions that we deem relevant to purchase insurance. This permits us to understand the risk of the medical condition declared against factors such as the destination chosen, duration of the holiday, and type of trip you have chosen to go on.

When we make a decision about you using automated processing which has a significant impact on you, we will let you know as part of your customer journey. You then have 21 days to ask us to reconsider our decision or to make a new decision using human intervention rather than automated processing. If we receive a request from you, within 21 days of receiving your request, we will:

consider the request, including any information you have provided that is relevant to it
meet your request; and
let you know in writing what we have done to meet your request and the outcome.

Your legal rights

You are entitled to the following:

A copy of the personal data we hold for you, by making a subject access request.
Have your data corrected if it’s wrong or incomplete.
Have your data deleted or removed if it’s no longer needed.
Restrict the processing of your personal data.
Withdraw any permission you’ve given in respect of your personal data (including marketing). You can unsubscribe by clicking on the unsubscribe button on our email communications or by contacting us directly.
Data portability – to keep and re-use your data in an electronic form for your own purposes or to ask we pass the information to another organisation.
Get human intervention on the part of the controller, where you are subject to a decision based solely on automated processing, including profiling, which has a significant effect on you, to express your point of view and/or to contest the decision.
Object where we’re processing your information on the grounds of it being our legitimate interest to do so.
We will uphold your rights to the best of our abilities; however, data protection laws allow us to continue to process your personal data if we have a legitimate reason, legal or contractual obligation to do so. For example, if data is needed for fraud prevention or legal requirements.
If you wish to exercise these rights set out above, please contact us. Should you wish to make a Subject Access you can do so by contacting us on the details provided above. You have the right to make the request verbally or in writing.

No fees usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. If another individual is making the request on your behalf, we will always ask for your explicit consent prior to sending your subject access request out to you via a secure method.

Time Limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Legitimate Interest

means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

Service providers acting as processors based in Ireland who provide their database to hold all our data;
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
Market researchers acting as the processor to provide the best customer experience;
Charities acting as processors to provide customers with gift aid;
Affiliates acting as processors that use advertising methods which include organic search engine optimisation (SEO), paid search engine marketing (PPC – Pay Per Click) and e-mail marketing;
Social Networks;
Customer Experience tools that show us your journey of how you navigate the website for a better understanding to improve your customer experience; and
Competition surveys.

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