Privacy Statement
ERGO WEBSITE – PRIVACY POLICY
ERGO Travel Insurance
Services Ltd – Privacy Policy
Last update May 2024
Introduction
ERGO
Travel Insurance Services Ltd (ERGO TIS) manages and administers your personal data
when you purchase an insurance policy from us. ERGO Travel Insurance Services
Ltd is collectively referred in this Privacy Policy as “we”, “us” or “our”.
Unless
otherwise indicated in your Policy Wording, ERGO Travel Insurance Services Ltd
is the controller of your personal data and therefore is responsible for your
personal data.
This Privacy Policy is
designed to help you, as a customer of ERGO Travel Insurance Services Ltd or as a person concerned in
connection with the insurance or settlement of claims (for example claimant,
injured party, etc.), to understand how we process your personal data. You are a
customer of ERGO
Travel Insurance Services Ltd and we are the underwriter on behalf Great
Lakes Insurance UK Limited of your policy.
However, you may have
purchased your insurance through an intermediary, e.g. through an insurance
broker or through an intermediary that we have authorised to issue a policy on
our behalf. Alternatively, we may need your information to check if an
insurance claim has occurred and how much the damage is.
The insurance lifecycle
respectively claims settlements may involve the sharing of your personal data
with other insurance market participants, some of which, you may not have
direct contact with. You can find out more information about these processors by
contacting the intermediary that you purchased your policy from.
Our contact details
|
Company Information |
|
Name: ERGO Travel Insurance Services Ltd Address: Afon House, Worthing Road, Horsham,
West Sussex, RH12 1TL, United Kingdom Phone Number: 01403 788513 E-mail: contact@ergo-travel.co.uk Website: www.ergotravelinsurance.co.uk
|
|
Data Protection Officer for ERGO Travel
Insurance Services Ltd |
|
Data Protection Officer Address: Afon House, Worthing Road, Horsham,
West Sussex, RH12 1TL, United Kingdom E-mail: dataprotectionofficer@ergo-travel.co.uk.
|
The
type of personal information we collect
We currently collect and
process the following types of personal data:
·
Individual information: Name, address, title,
date of birth, nationality, residence, family details and their relationship to you.
·
Policy information: Information about the
quotes and insurance policies you have applied for or taken out.
·
Financial Information: Premiums and claims
paid on your policies. Bank account or payment card details. Income and other
financial information.
·
Statutory and anti-fraud information: sanctions and
information from anti-fraud databases concerning you.
·
Claim information: information about previous and current claims.
·
Individual and claim Information: Gender and health
information. Medical reports. Criminal records and convictions.
·
Statutory and anti-fraud information: Criminal records and
convictions.
·
Personal data concerning health: Medical history
and medical data.
How
we get the personal information and why we have it
Most of the personal
information we process is provided to us directly by you at the time to
purchase an insurance product with us.
We also collect your personal
data through our processors who are acting on our behalf.
The details of how we collect
your personal data, purposes of processing and our lawful basis for processing
are detailed below:
|
Categories
of personal data |
Where
the personal data may come from |
Purposes
of processing |
Lawful
basis of processing |
|
Individual Information |
·
Directly from the insured ·
Insurance intermediaries or other
insurance market participants ·
Insured’s family
|
·
Setting you up as a client including
checks for potential fraud, sanctions, credit and anti-money laundering ·
Managing you as a client including underwriting,
evaluating and pricing of the risks to be insured and calculating and
validating the appropriate premium for your policy ·
The automated and non-automated
provision of Insurance to insureds, as set out on the insurance contract ·
Statistical analysis. |
·
Performance of our contract with you ·
Consent ·
Legitimate interest from agents,
brokers, insurance companies and other interested parties. |
|
Policy Information |
·
Directly from the insured ·
Insurance intermediaries or other
insurance market participants ·
Insured’s family ·
Your employer |
·
Managing you as a client including underwriting,
evaluating and pricing of the risks to be insured and calculating and
validating the appropriate premium for your policy ·
The automated and non-automated
provision of Insurance to insureds, as set out on the insurance contract ·
Statistical analysis |
·
Performance of our contract with you ·
Consent ·
Legitimate interest from agents,
brokers, insurance companies and other interested parties |
|
Financial Information |
·
Directly from the insured ·
Insurance intermediaries or other
insurance market participants ·
Insured’s family ·
Your employer
|
·
Managing you as a client including underwriting,
evaluating and pricing of the risks to be insured and calculating and
validating the appropriate premium for your policy ·
The automated and non-automated
provision of Insurance to insureds, as set out on the insurance contract ·
Statistical analysis |
·
Performance of our contract with you ·
Consent ·
Legitimate interest from agents,
brokers, insurance companies and other interested parties |
|
Statutory and anti-fraud information |
·
Directly from the insured ·
Insurance intermediaries or other
insurance market participants ·
Insured’s family ·
Your employer ·
Anti-fraud databases ·
Sanctions lists |
·
Setting you up as a client including
checks for possible fraud, sanctions, credit and anti-money laundering ·
Managing you as a client including
underwriting, evaluating and pricing the risks to be insured and calculating,
validating and collecting any appropriate premium |
·
Performance of our contract with you ·
Compliance with a legal obligation ·
Processing is necessary for the defence
of legal claims |
|
Claim Information |
·
Directly from the insured ·
Insurance intermediaries or other
insurance market participants ·
Insured’s family ·
Your employer ·
Anti-fraud databases, claimants,
defendants, witnesses, experts inc. medical experts, loss adjustors,
solicitors and claims handlers |
·
Managing insurance and reinsurance
claims ·
Defending or prosecuting legal claims ·
Investigating or prosecuting fraud ·
Statistical analysis |
·
Performance of our contract with you ·
Compliance with a legal obligation ·
Consent ·
Processing is necessary for the defence
of legal claims ·
Legitimate interest from agents,
brokers, insurance companies and other interested parties |
|
Individual and claim Information |
·
Directly from the insured ·
Insurance intermediaries or other
insurance market participants ·
Insured’s family
|
·
Setting you up or managing you as a
client. Evaluating and pricing the risks to be insured and calculating and
validating any appropriate premium ·
Claims administration ·
The automated and non-automated
provision of Insurance to insureds, as set out on the insurance contract ·
Statistical analysis |
·
Performance of the insurance contract
with you ·
Consent ·
Processing is necessary for the defence
of legal claims |
|
Personal Data concerning health |
·
Directly from the insured ·
Insurance intermediaries or other
insurance market participants ·
Insured’s family
|
·
The automated and non-automated
provision of Insurance to insureds, as set out on the insurance contract ·
Evaluating and pricing the risks to be
insured and calculating and validating any appropriate premium |
·
Performance of the insurance contract
with you ·
Consent
|
Who
your data is shared with
The following are data
controllers that we share your personal data with:
·
Great Lakes Insurance UK Limited and other
companies within ERGO Group.
·
Agents – that sell insurance products on our
behalf.
·
Brokers – that have advised our insurance
products to you.
·
Government Agencies.
·
Legal advisers.
The following are data
processors that we disclose your personal data to:
·
Third Parties providing services for Banking.
·
Claims Handling.
·
Assistance Providers.
·
Insurance Administration.
·
IT Services.
Please contact the Data
Protection Officer (dataprotectionofficer@ergo-travel.co.uk.) if you require further
information on who your data is shared with.
You can find out more
information concerning the recipients of your personal data in your policy
wording and the privacy policy of the intermediary that you purchased your
policy from.
Protection
of your information
Your privacy is important to
us and we follow strict security and organisational procedures in the
processing, storage, destruction and disclosure of your information. This is to
prevent unauthorised access or loss of your information.
Use
of your Consent to process Special Categories of Personal Data
In order to provide insurance
or to carry out claims settlements, in certain circumstances, we may need to
process special categories of personal data, such as medical records or
criminal conviction data.
We follow the lawful basis of
the performance of the insurance contract and explicit consent. If explicit consent
is used, you may have given your explicit consent directly to us or to the
insurer that you purchased your policy from.
As far as claim settlement is
concerned, the legal basis is also the performance of the contract or, if
special categories of personal data are required (for example, your health data
when examining the claim), we will seek your explicit consent. You may withdraw
your consent for us to process your special categories of personal data at any
time by contacting the Data Protection Officer (details as above).
However, if you withdraw your
consent this will impact on our ability to provide or continue to provide
insurance for your insurance policy or pay claims.
Call
Monitoring and Recording
For quality control purposes
and to audit the evaluation process for the underwriting and pricing of the
risks to be insured, we may review copies of telephone recording made with the
intermediary that you purchased your policy from.
Data
Retention
Your personal data will only
be kept for as long as it is necessary for the purpose it was collected for. We
normally keep your personal data for 7 years after the end of the insurance
agreement between and us and you. We can keep your personal for longer time, for
example, for claims and court proceedings.
Please contact the Data
Protection Officer (dataprotectionofficer@ergo-travel.co.uk.) if you require further
information concerning the retention period of your personal data.
Transfer
of Data
We will not transfer your
personal data outside the UK or EEA where there is not an adequate level of
data protection.
Your personal data may be
disclosed to companies within our Group or to Service Providers outside the UK
or EEA. However, we ensure that there is an adequate level of data protection
in place and adhered to by these parties.
You can find out the details
about any other party we have shared your personal data with by contacting the
Data Protection Officer at the address provided at the top of this information
notice, in your policy wording and the privacy policy of the intermediary that
you purchased your policy from.
Automated
Decision Making
As part of processing of your
personal data, decisions may be made automatically, for example to calculate
premiums for pre-existing medical cover.
We will inform you of the
existence of automated-decision making in your policy wording.
You have a right to challenge
these automated systems.
When booking we use your data
to make sure you are who you say you are. If your data is inconsistent with
your previous submissions; or you appear to have, on purpose, hidden your true
identity we will prevent you from booking with us.
To calculate premiums for
pre-existing medical cover. We use a processor to work out a risk score for us.
Verisk is the organisation that helps us here and is used across the industry
by other insurance providers. Verisk will make some automated decisions about
you which will be based on comparing you with other people.
Your
data protection rights
Under data protection law, you
have rights including:
·
Your
right of access – You have the right to ask us for copies of
your personal information.
·
Your
right to rectification – You have the right to ask us to rectify
personal information you think is inaccurate. You also have the right to ask us
to complete information you think is incomplete.
·
Your
right to erasure – You have the right to ask us to erase your
personal information in certain circumstances.
·
Your
right to restriction of processing – You have the right to ask
us to restrict the processing of your personal information in certain
circumstances.
·
Your
right to object to processing – You have the the right to object to the processing of your personal
information in certain circumstances.
·
Your
right to data portability – You have the right to ask that we
transfer the personal information you gave us to another organisation, or to
you, in certain circumstances.
You are not required to pay
any charge for exercising your rights. If you make a request, we have one month
to respond to you.
Please contact the Data
Protection Officer if you wish to make a
request.
How to complain
If you have any concerns about
our use of your personal information, you may contact our Data Protection Officer at the aforementioned
address, or via the e-mail address dataprotectionofficer@ergo-travel.co.uk.
You can also complain to the
ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information
Commissioner’s Office
Wycliffe
House
Water
Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
