PRIVACY NOTICE

Effective Date: 24/03/2021

INTRODUCTION

ETI is a trading name of ERGO Travel Insurance Services Ltd.

ERGO Travel Insurance Services Ltd manages and administers your data when you purchase an insurance policy from us. ERGO Travel Insurance Services Ltd is the controller and is responsible for your personal data collectively referred to as ERGO Travel Insurance Services Ltd, "we", "us" or "our" in this privacy notice..

ERGO Travel Insurance Services Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will tell you how we look after your personal data when you visit our website, mobile apps or through authorised third-party agents (regardless of where you visit from) and will inform you about your privacy rights and how the law protects you.

1. WHO WE ARE AND IMPORTANT INFORMATION

THE PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how we collect and process your personal data through your use ofour websites, mobile apps or through authorised third-party agents when purchasing insurance with us. This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

ERGO Travel Insurance Services Ltd is the controller of your data and will do its utmost to protect the data provided by you. Please read this privacy notice to understand how your personal data is being processed. We will let you know how we use your data. ERGO Travel Insurance Services Ltd is the controller and responsible for this policy.

CONTACT DETAILS:

Our full details are:
Full name of legal entity: ERGO Travel Insurance Services Ltd
(Registered in England No. 11091555)
Title: Data Protection Officer
Email address: dataprotectionofficer@ergo-travel.co.uk
Postal address: Afon House, Worthing Road, Horsham, West Sussex, RH12 1TL
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

The Information Commissioner can be contacted at:
www.ico.org.uk, or by post at:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire,SK9 5AF

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 16 March 2021, historic copies are archived, copies can be obtained by contacting us.

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 notice of every website you visit.

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).

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, postal address, email address and telephone numbers.
• Financial Data includes bank account and payment card details to purchase a policy. Financial data will be encrypted accordingly.
• 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 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 our third parties and your communication preferences.
• Health and Medical Information includes medical history obtained from you.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

We do collect Special Categories of Personal Data about you. This is subject to your health and when you use our online customer journey, we will obtain your medical history and medical data to calculate your premium and to process your purchase with us.

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 purchasing insurance products through our website online, including correspondence with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • 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.

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 our obligations within your contract we are about to enter into or have entered into 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 obtain consent to send any marketing materials.
• Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

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.

Email address: customerservice@ergo-travel.co.uk

Postal address: Afon House, Worthing Road, Horsham, West Sussex, RH12 1TL

Purpose for which we will use your personal data

Below is a description of the ways we may use your personal data, this includes the legal basis we rely on to do so. On the basis that we use your personal data under the grounds of Legitimate Interests we will compile and record a Legitimate Interest Assessment to protect your rights and freedoms, this will be reviewed at least annually. We may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. If you would like details about the specific legal grounds, we are relying on to process your personal data please contact us.

Purpose	Type of data	Lawful basis for processing including basis of legitimate interest
For you to receive a quote	Identity Contact Health and Medical Information Financial	Performance of a contract with you
To process and deliver your product and services including: Collecting medical data Providing medical assistance abroad Claims handling Manage payments, fees and charges	Identity Contact Financial Transaction	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) For the defence of legal claims
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy notice 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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business) Consent (to inform our marketing strategy
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 make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services) Consent (to and grow our business

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established methods to provide you 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

You will receive marketing communications from us if you have requested information from us or purchased insurance products from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

SHARING INFORMATION WITH A THIRD-PARTY

We do not sell, otherwise disclose, or share information we collect and hold about you, except as described in this Privacy Notice.

We share personal information with third parties who perform services on our behalf. For example, we may use third parties to host our websites or mobile apps, manage and support insurance applications and store data, send e-mails, print or send mailings, administer the sale of our insurance, provide medical screening, provide pre-trip advice, conduct customer research, authorise and process your payments, manage and analyse data, handle claims and provide assistance services.

These third parties are not authorised by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements. Any personal information shared with such third parties is protected as described below.

Subject to applicable law, we may also share the personal information we obtain with our affiliates, subsidiaries and other group companies. If we share your personal information with such persons, we will ensure that an adequate level of protection is in place to protect your personal information in accordance with applicable law.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time 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 purchase.

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 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 have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary, which ETI will be in a legal binding contract.
• If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or
• From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it.

The security of your data is important to us and we require any third parties to respect 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. DATA SECURITY

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 instruction and they are subject to a duty of confidentiality.

Our IT systems are protected by hardware based firewall systems, with scans being performed regularly to ensure that any vulnerabilities are quickly found and patched. Annual penetration tests are performed by external parties. All services have auto fail-over points and redundant hardware, with complete backups performed as a minimum daily. Access to systems is severely restricted to specific individuals, whose access is monitored and audited.

We have 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.

7. RETENTION

HOW LONG WILL YOU KEEP MY PERSONAL DATA FOR?

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.

After your policy expires with us, we may keep your data for up to 7 (seven) years.

8. YOUR LEGAL RIGHTS

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

You may have the right to:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing of your personal data
• Withdraw consent at any time

If you change your mind and no longer wish to receive marketing communications from us, you have the right to request that we cease sending marketing communications, whether by email or otherwise, to you.

You can do this by:

• checking the applicable box(s) on any form we may use to collect information from you;
• clicking the unsubscribe link displayed in any of our marketing e-mails; or
• otherwise requesting that we do not process your information for marketing purposes.

You can withdraw any consent given to us at any time and free of charge, but you may no longer be able to benefit from our services if you do so.

To exercise these rights or to make a complaint or submit an enquiry about our privacy practices, please contact us by email at dataprotectionofficer@ergo-travel.co.uk

or write to us at:

Data Protection Officer ERGO Travel Insurance Services Ltd, Afon House, Worthing Road, Horsham, West Sussex, RH12 1TL, United Kingdom

NO FEE USUALLY PAYABLE

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 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.

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.

9. GLOSSARY

LAWFUL BASIS:

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

External Third Parties:

• 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;
• Fraud prevention agencies acting as processor to prevent any fraud activities that may occur;
• Market researchers acting as processor to provide the best customer experience;
• Price comparison websites and similar companies that offer ways to research and apply for financial products and services, such as aggregators;
• Customer Experience tools that shows us your journey of our purchasing travel insurance product for a better understanding to improve your customer experience;
• Competition surveys.
• Medical assistance acting as data controller to provide medical assistance on behalf of ERGO Travel Insurance Services Ltd's emergency medical assistance.

YOUR LEGAL RIGHTS

1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that 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.
4. 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that 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. However, 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.