LAST UPDATED: 17th December 2015
Direct Travel Insurance is a trading style of Intermediated Services Ltd (ISL) which is authorised and regulated by the Financial Conduct Authority FCA No: 501719.
ISL is registered in the UK with Company House No: 06902336. Dalesridge Ltd is the parent company of ISL; Dalesridge Company House Number: 7669842. Both Companies Registered Office: 29a Crown Street, Brentwood, Essex, CM14 4BA.
The customer, consumer, policy holder or those seeking quotations of insurance policies shall be handled by ISL our regulated company. Additionally where applicable for Dalesridge customers for the purpose of this document reference to ISL shall encompass Dalesridge.
- this website (the "Site");
- the software applications made available by us for use on or through computers, tablets and mobile devices;
- our social media pages
- other marketing and related communications
(collectively (including the Site, Social Media Content, and other marketing related communications) referred to below as the "ISL Services, whether ISL Electronic Services or otherwise"),
and through other means (for example, from your application and claim forms, telephone calls, emails and other communications with us, as well as from claim investigators, medical professionals, witnesses or other third parties involved in our business dealings with you).
- Who To Contact About Your Personal Information
- Personal Information That We Collect
- How We Use Personal Information
- International Transfer of Personal Information
- Sharing of Personal Information
- Retention of Personal Information
- Personal Information of Other Individuals
- Marketing Preferences
- Access and Correction Requests, Questions and Concerns
- Other Information We Collect Through ISL Services
- Third Party Websites
- Use of ISL Services by Minors
1. Who To Contact About Your Personal Information
If you have any questions about our use of your Personal Information you can email: firstname.lastname@example.org or write to the Compliance Director and/or Data Protection Officer, ISL Digital House, Threshelfords Business Centre, Feering, Colchester, Essex. CO5 9SE
2. Personal Information That We Collect
Depending on your relationship with us (for example, as a consumer policyholder; non-policyholder insured or claimant; witness; commercial broker or appointed representative; or other person relating to our business), Personal Information collected about you and your dependants may include:
- General identification and contact information Your name; address; email and telephone details; gender; marital status; family status; date and place of birth; passwords (including on our systems); educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; all information declared to ISL and where applicable to include declared health conditions, relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.
- Identification numbers issued by government bodies or agencies Social Security or national insurance number; passport number; tax identification number; military identification number; or driver's or other license numbers and/or numbers related to identification that you have shared with ISL.
- Financial information and account details Payment card number; bank account number and account details; credit history and credit score; assets; income; and other financial information.
- Medical condition and health status Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.
- Other sensitive information In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organisation). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).
- Telephone recordings Recordings of telephone calls to our representatives and call centres. Information to investigate crime, including fraud and money laundering For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
- Information enabling us to provide products and services Where appropriate and provided to us any information about location and identification of property insured (for example, property address, vehicle license plate or identification number); travel arrangements including reservation numbers; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organisation; and other insurance you hold.
- Marketing preferences and customer feedback You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.
- Social media account and information from Apps or other We may receive certain Personal Information about you when you respond to surveys, personal enquires, or use Social Media Content, including your social media account ID and profile picture, and other Personal Information that you provide to us. If you elect to connect your social media account provided by another social media service provider to your account(s) on any of the ISL Services, Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your social media account profile or your friends' profiles.
3. How We Use Personal Information
We use this Personal Information to:
- Communicate with you and others as part of our business.
- Send you important information regarding changes to our policies, other terms and conditions, the ISL Services and other administrative information.
- Make decisions about whether to provide insurance; provide insurance and assistance services, including claim assessment, processing and settlement; and, where applicable, manage claim disputes.
- Assess your eligibility for payment plans, and process your premium and other payments.
- Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
- Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
- Carry out market research and analysis, including satisfaction surveys. Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.
- Personalise your experience on the ISL Electronic Services by presenting information and advertisements tailored to you.
- Identify you to anyone to whom you send messages through the ISL Electronic Services.
- Allow you to participate in contests, prize draws and similar promotions, and to administer these activities.Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully.
- Facilitate social media sharing functionality.
- Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.
- Resolve complaints, and handle requests for data access or correction. Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
- Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
4. International Transfer of Personal Information
Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries (including the United States and other countries that have a different data protection regime than is found in the country where you are based). For example, we may transfer Personal Information in order to process international travel insurance claims and provide emergency medical assistance services when you are abroad. We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities.
5. Sharing of Personal Information
ISL may make Personal Information available to:
Other insurance and distribution parties: In the course of marketing and providing insurance and processing claims, ISL may make Personal Information available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; distributors; affinity marketing partners; and financial institutions, securities firms and other business partners.
Our service providers: External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers; call centre service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; third-party claim administrators; document and records management providers; claim investigators and adjusters; construction consultants; engineers; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
Governmental authorities and third parties involved in court action: ISL may also share Personal Information with governmental or other public authorities (including, but not limited to, statutory agencies, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, adjusters, solicitors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
Other Third Parties: We may share Personal Information with payees; emergency providers (fire, police and medical emergency services); retailers; medical networks, organisations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganisation, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock. To check information provided, and to detect and prevent fraudulent claims, Personal Information (including details of injuries) may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to detect, prevent and investigate fraud.
Personal Information may also be shared by you, on message boards, chat, profile pages and blogs, and other ISL Electronic Services to which you are able to post information and materials (including, without limitation, our Social Media Content). Please note that any information you post or disclose through these services will become public information, and may be available to visitors and users of the ISL Electronic Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, when using the ISL Electronic Services.
ISL will take appropriate technical, physical, legal and organisational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. (See the "Who to Contact About Your Personal Information" section above.) When ISL provides Personal Information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information.
7. Retention of Personal Information
8. Personal Information of Other Individuals
9. Marketing Preferences
We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. To tell us your marketing preferences and to opt-out, you can also contact us by email email@example.com or by writing to: Marketing Preference Team, ISL Digital House, Threshelfords Business Centre, Feering, Colchester, Essex. CO5 9SE
- Receiving email messages and text messages from us: If you no longer want to receive marketing-related emails or text messages from ISL on an ongoing basis, you may opt-out of receiving these marketing-related messages by clicking on the link to "unsubscribe" provided in each message or by contacting us at the above addresses.
- Receiving telephone communications and postal mail from us: If you no longer want to receive mobile messages, telephone communications or postal mail, email from ISL on an ongoing basis, you may opt-out of receiving these marketing-related communications by contacting us at the above addresses.
- Our sharing of your Personal Information with our group companies for their marketing purposes: If you would prefer that we do not share your Personal Information on an ongoing basis with our group companies for their own marketing purposes, you may opt-out of this sharing by contacting us at the above addresses.
- Our sharing of your Personal Information with selected third-party partners for their marketing purposes: If you have provided your consent we may share your Personal Information on an ongoing basis with our third-party partners for their own marketing purposes. If you change your mind, you may opt-out of this sharing on an ongoing basis by contacting us at the above addresses.
We aim to comply with your opt-out request(s) within a reasonable time period. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e., to those to whom we have already provided your Personal Information as of the date on which we respond to your opt-out request). Please also note that if you do opt-out of receiving marketing communications from us, we may still send you other important administrative communications from which you cannot opt-out.
10. Access and Correction Requests, Questions and Concerns
In certain countries, an individual may have the right to access, correct or object to the use of, or request deletion or suppression of Personal Information on certain grounds. Please contact us as set out in the "Who to Contact About Your Personal Information" section above with any such requests or if you have any questions or concerns about how we process Personal Information. Please note that some Personal Information may be exempt from access, correction, objection, deletion or suppression rights in accordance with local privacy and data protection laws.
11. Other Information We Collect Through ISL Electronic Services and other Services "Other Information" is any information that does not reveal your specific identity, such as:
- Browser and electronic device information;
- App usage data;
- Information collected through cookies, pixel tags and other technologies;
- Demographic information and other information provided by you; and
- Aggregated information
Other Information We Collect
We and our third-party service providers may collect Other Information in a variety of ways, including:
- Through your internet browser or electronic device: Certain information is collected by most websites or automatically through your electronic device, such as your IP address (i.e., your computer's address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, electronic device manufacturer and model, language, time of the visit, page(s) visited and the name and version of the ISL Electronic Services (such as the App) you are using.. We use this information to ensure that the ISL Electronic Services function properly.
- Through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your electronic device accesses our servers and what information and files have been downloaded to the App based on your device number.
Below is a description of some of the type of cookies we use, or may use on our UK websites, what they do, what data about you they collect and what we use them for:
- Geo Location cookie: When a visitor visits one of our sites for the first time we read their location from their IP address and use this information to assume the country site that they want to visit. This method is not entirely accurate, however, so when they navigate to a particular country site we use a cookie to store this information and to store the language that they chose to view the site. The next time they visit the site we read the cookie and present the same country and language version they used on their last visit. This has the intended benefit that they don't need to reselect the country site they need each time they visit an ISL site. No Personal Information is collected or used by the cookie.
- Site Catalyst cookie (by Adobe): This cookie enables us to collect and analyse data about how visitors arrive at our site and then how they interact with our site, including products they may search, content they may view, and the steps leading up to a completed or abandoned sale. We use this aggregated information to adapt our sites to better serve their and other users' needs and interests, and to provide more relevant and useful information. The cookie is placed on a visitor's PC on a temporary basis only. The cookie does not collect or use their Personal Information. Instead, it logs an anonymous code which identifies users and this code "follows" the user in their journey through the site. We use the aggregated and anonymous information for statistical analysis.
- DoubleClick cookies and/or other similar cookies: We place a tracking pixel cookie on to all site visitors' computers for the purpose of our banner advertising activity. We use these cookies to know that a visitor has been on our site before which allows us to display an appropriate banner ad on to an affiliated network website. No Personal Information is collected. One of the advertisement companies that we may use is Google, Inc, trading as DoubleClick. For more information on the DoubleClick cookie, or to opt out from the DoubleClick advertisement cookie please visit: www.google.com/privacy/ads/.
- • Affiliate cookie: We use a tracking pixel cookie, which is put on a visitor's PC and collects only the transaction ID (which identifies the affiliated website the visitor has come from) and a time and date stamp. This enables our affiliate network partners to track affiliated sales and ensure an affiliate is credited for a sale referred to us. It does not involve any passing of Personal Information.
- SessionCam or other cookie with a similar: We also may use the SessionCam web site recording service. SessionCam is a product that has been developed by www.servicetick.com. SessionCam may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. The information collected does not include bank details or any sensitive information and it is for internal use only. Information collected is used to improve our website usability and is stored and used for aggregated and statistical reporting.
You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products. We may from time to time vary or alter the cookie software providers and these details provided herein are provided as example and not intended to be exclusive to other such cookies or software that we may utilise.
- Using pixel tags, web beacons, clear GIFs or other similar technologies: These may be used in connection with some ISL Electronic Services and HTML-formatted email messages to, among other things, track the actions of users of the ISL Electronic Services and email recipients, measure the success of our marketing campISLns and compile statistics about usage of the ISL Electronic Services and response rates.
- Physical Location: Subject to applicable law, we may collect the physical location of your electronic device by, for example, using satellite, mobile/cell phone tower or WiFi signals. We may use your device's physical location to provide you with Personalised location-based services and content. Subject to your marketing preferences as indicated to us or applicable law, we may also share your device's physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more Personalised content and to study the effectiveness of advertising. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device's location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable Personalised services and content.
- From you: Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you.
By aggregating information: We may aggregate and use certain information (for example, we may aggregate information to calculate the percentage of our users who have a particular telephone area code). Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the "Other Information We Collect" section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.
12. Third Party Websites
13. Use of ISL Electronic Services by Minors
The ISL Electronic Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information directly through the ISL Electronic Services.
Intermediated Services Ltd