Privacy policy.

Introduction

We respect your privacy and are committed to protecting your personal data. This privacy policy will tell you how we look after your personal data, your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

Who this privacy policy applies to

This privacy policy applies to individuals (“you”) whose personal data we collect in relation to the quotation, sale, use and administration of our insurance products and insurance aggregator services by all channels and includes claims. This includes actual and potential policyholders, beneficiaries of insurance products, third party claimants and other third parties set out in the Third Parties section.

Purpose of this privacy policy

This privacy policy tells you how we collect and process your personal data through:

– your use of the websites of any of the companies within our group, including any data you may provide through such websites when you make an enquiry about, use or purchase a product or services; and/or

– any interaction between you and any of the companies within our group through any other sales, service or claims channels, including where your personal data is provided to us by a third party.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

We would also recommend that you read the Lloyd’s Market Association’s Insurance Market Core Uses Information Notice (available at https://londonmarketgroup.co.uk/gdpr). This is an insurance market standard information notice which explains in more detail how the insurance market works and uses personal data to provide insurance cover, particularly in relation to the Lloyd’s Market Association where multiple organisations can be involved in the underwriting and administration of insurance products.

This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

The Staysure Group Limited is made up of different legal entities which are:

• TiCORP Limited
• Wapp Limited
• Rock Insurance Services Limited
• Eclipse Financial Management Limited
• Howserv Limited
• Howserv Services Limited

This privacy policy is issued on behalf of the Staysure Group Limited so when we mention “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Staysure Group responsible for processing your data. When you enquire about, purchase or use a product or service from us we will let you know which entity will be the controller of your personal data.

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

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Email address: [email protected]

Postal address: Britannia House
3-5 Rushmills Business Park
Bedford Road
Northampton
NN4 7YB

Telephone number: (01604) 552879

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 do contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 30th September 2024.

It is important that the personal data we hold about you is accurate and current. 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 policy of every website you visit.

Our Group

We are a family of several travel and pet insurance brands. Our group currently includes:

2. 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).

The personal data we collect may vary across our product range. If you are a policyholder or a prospective policyholder, or if you are the beneficiary of a policy, please see below for more information about the personal data we collect in relation to each product. If you are a Third Party, please see the Third Parties section.

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

Pet insurance

• Identity Data includes name and any former names, username or similar identifier, title, date of birth and gender.
• Contact Data includes postal address, email address and telephone numbers.
• Damage Data includes information about loss or damage (including injury or illness suffered by your pet) in relation to which you are making a claim under your policy.
• Financial Data includes bank account and payment card details.
• Health Data includes information about your pets health if relevant to an element of cover under your policy.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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 our websites.
• Profile Data includes information about your enquiries and/or purchases, the number and type of pet(s) you have, the risk insured or to be insured, claims, interests, preferences and feedback.
• Usage Data includes information about how you use our websites, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Individual Travel Insurance

• Identity Data includes name and any former names, username or similar identifier, title, date of birth and gender.
• Contact Data includes postal address, email address and telephone numbers.
• Damage Data includes information about loss or damage in relation to which you are making a claim under your policy.
• Financial Data includes bank account and payment card details.
• Health Data includes information about your health including known medical conditions and/or injuries sustained in relation to an insured incident.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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 our websites.
• Location Data from your mobile device when you travel under insurance provided by WAPP Limited
• Profile Data includes information about your enquiries and/or purchases, the risk insured or to be insured, claims, interests, preferences and feedback.
• Usage Data includes information about how you use our websites, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Gadget Insurance

• Identity Data includes your name, username or similar identifier, title and job title.
• Contact Data includes business address, work email address and work telephone numbers.
• Damage Data includes information about loss or damage in relation to which your employer or you as an individual is making a claim under the policy.
• 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 our websites.
• Profile Data includes information about the risk insured or to be insured and claims.

Third Parties

In the course of conducting our insurance business, we expect to collect and process personal data relating to the following categories of individuals whom we refer to in this privacy policy as Third Parties:

• Contacts at corporate insurance clients
• Third party claimants under a policy which offers third party liability cover;
• Witnesses to an insured incident;
• Individuals who have caused any of our policyholders a loss;
• Legal representatives, legal advisers and claims handlers;
• Medical professionals;
• Practitioners of veterinary medicine and other veterinary staff;
• Expert witnesses or other expert service providers;
• Approved Persons
• External providers of payment solutions

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

• Identity Data includes name and any former names, title, date of birth and gender.
• Contact Data includes your residential address or work postal address, email address and telephone numbers.
• Damage Data includes information about loss or damage which you have sustained and for which you hold our policyholder responsible.
• Health Data includes information about your health including injuries sustained in relation to an insured incident.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Other than Health Data where necessary for insurance purposes, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data).

We may collect information about criminal allegations, convictions and offences (Criminal Data) in relation to our customer or Approved Person due diligence activity, anti-money-laundering and anti-fraud checks or if we need to know about it in relation to insurance claims.

If you do not provide personal data when it is requested

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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. 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 filling in online or paper forms or by corresponding with us by post, phone, email, live chat or otherwise. This includes personal data you provide when you:- Enquire about, apply for and/or purchase our products or services;
  – Provide services to us;
  – create an account on any of our websites;
  – make a claim against any policy;
  – request marketing to be sent to you;
  – enter a competition, promotion or survey; or
  – complain, give us feedback or generally contact us.When you contact us by phone, we may use artificial intelligence to ask you for some of the information we will need to handle your call. This is to reduce the time you need to spend on the phone with us and increase the accuracy of the data we collect.
• Indirect interactions. We may receive your Identity Data, Contact Data and, where applicable, Damage and/or Health Data from our policyholders where you are a beneficiary under a product or a family member of such a beneficiary or we may receive such information from your representatives (including legal representatives or insurer) where you are a third party claimant.
• Automated technologies or interactions. As you interact with any of our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the Cookies section for further details. For customers of WAPP Limited, this includes Location Data from your mobile device whilst travelling under the cover of a WAPP Limited policy.
• Intragroup referrals. Where you have applied for a product of service with one of our group companies which is declined for any reason, your information may be shared with other members of our group who may be able to provide the relevant product or service instead.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:- Technical Data from analytics providers, advertising networks and search information providers;
  – Identity and Contact Data from your employer if you are a contact of ours or an Approved person;
  – Identity, Contact and Health data from your employer where you are covered under a business travel insurance policy;
  – Identity, Contact, Damage and Health Data from the insurer of your policy (if not underwritten by the Staysure Group);
  – Identity, Contact, Damage and Health Data from third parties in the insurance sector involved with the provision and administration of your policy, including claims investigators;
  – Contact, Financial and Transaction Data from providers of technical, payment, fulfilment and delivery services;
  – Health Data from medical professionals;
  – Profile and Damage Data from veterinary staff (for pet insurance only);
  – Identity and Contact Data from financial crime or fraud agencies, databases and sanctions lists;
  – Identity and Contact Data from credit reference agencies;

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you or take steps at your request before entering into such a contract with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although WAPP Limited customers will be asked for their consent for the processing of Location Data. We will also ask for your consent for members of our group to send you marketing messages (see the Marketing section). You do not need to give consent just because we ask for it.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you would like further details about this.

If you are not a policyholder, prospective policyholder, or a beneficiary please click on the Third Parties section below for information about how we use your personal data.

Pet Insurance

Individual Travel Insurance

Gadget Insurance

Third Parties

Automated Decision-Making

We may use automated processes to make decisions about you

Marketing

We want to provide you with choices about marketing and advertising.

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 or purchased products or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party or company outside of our group for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time following the opt-out links on any marketing message sent to you or by contacting us at any time.

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 or service purchase or experience or other transactions.

Cookies

You can set your browser to tailor cookies based on your preferences, 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 the 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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out this privacy policy.

• Other members of Staysure Group Limited who may be able to provide you with a product or service which you have enquired about and which we are unable to provide to you;
• Service providers who provide IT and system administration services and other business systems and processes;
• Professional advisers including lawyers, bankers, auditors and reinsurers who provide consultancy, banking, legal, insurance and accounting services;
• Insurers, where the relevant policy is not underwritten by the Staysure Group;
• HM Revenue & Customs, regulators and other authorities;
• Anti-fraud, anti-money laundering and law enforcement bodies, including the police;
• Civil and criminal courts;
• Industry bodies and other members of the insurance industry involved in the provision of your insurance cover, including insurers (where the relevant policy is not underwritten by the Staysure Group), reinsurers loss adjusters, insurance administrators and claims handling companies;
• Medical professionals for the provision of medical reports or access to health records;
• Third party insurers;
• Credit reference agencies; and
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within the Staysure Group. This will involve transferring your data outside the UK.

Many of the third parties we work with are based outside the UK so their processing of your personal data will also involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. 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.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we are able to use this information indefinitely.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to a copy of your personal data

Request correction of the personal data that we hold about you.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes or. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Finally, you may object to our use of automated decision-making. For more information about this, see the ICO’s guidance here.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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 could refuse to comply with your request in these circumstances. We may, to keep your personal information secure, need to request specific information from you to help us confirm your identity.