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PRIVACY POLICY

This Privacy Policy is effective from 22nd May 2018.

The data controller is identified as Brokersure Group Ltd. Direct Travel Insurance is a trading style of Brokersure Ltd which is authorised and regulated by the Financial Conduct Authority FCA No: 501719. Brokersure Ltd is registered in the UK with Company House No: 06902336. Brokersure Group Ltd is the parent company of Brokersure Ltd, Company House Number: 7669842. Both Companies Registered Office: 6 The Square, Martlesham Heath, Ipswich, IP5 3SL. Brokersure Group Ltd and Brokersure Group operate out of Digital House, Threshelfords Business Park, Inworth Road, Feering, Essex CO5 9SE

The customer, consumer, policy holder or those seeking quotations of insurance policies shall be handled by Brokersure Ltd, our regulated company.

This Privacy Policy describes how we handle Personal Information that we collect both through:

  1. This website (the "Site");
  2. The software applications made available by us for use on or through computers, tablets and mobile devices;
  3. Our social media pages
  4. Other marketing and related communications referred to below as electronic services
  5. Call Centre
  6. Service related channels including Underwriting, Claims and Medical Assistance

To learn about how we are processing your Personal Information, please click on the links below:

  1. Who to Contact About Your Personal Information
  2. Personal Information That We Collect
  3. How We Use Personal Information
  4. International Transfer of Personal Information
  5. Sharing of Personal Information
  6. Security
  7. Retention of Personal Information
  8. Personal Information of Other Individuals
  9. Marketing Preferences
  10. Access and Correction Requests, Questions and Concerns
  11. Other Information We Collect Through Brokersure Ltd Services
  12. Third Party Websites
  13. Use of Brokersure Ltd Services by Minors
  14. Changes to This Privacy Policy

We collect and process your personal information in accordance with our Privacy Policy which includes details about our use of cookies.

1. Who to Contact About Your Personal Information

If you have any questions about our use of your Personal Information or wish to withdraw consent for us to use your data or wish to know what information we hold,you can email: dataprotectionofficer@brokersure.com or write to Mr. Andy Taylor, Data Protection Officer, Brokersure Ltd, Digital House, Threshelfords Business Park, 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:

  1. General identification and contact information - Your name; address; email and telephone details; gender; marital status; date of birth; passwords (including on our systems); physical attributes; activity records, such as driving records; all information declared to Brokersure Ltd and where applicable to include declared health conditions, relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.
  2. Financial information and account details - Payment card number, although these details are not stored on our systems.
  3. 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.
  4. Other sensitive information - In certain cases, we may receive sensitive information about your trade, 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). 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).
  5. Telephone 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.
  6. 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; 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; and other insurance you hold.
  7. 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.
  8. Social media account and information from Apps or other - We may receive certain Personal Information about you when you respond to surveys, personal enquiries, 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 electronic 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.

In accordance with current legislation, we would advise you that any data requested from you will be held securely and will only be used for the reasons of managing the contract of business we are arranging for you or for purposes where we have a legitimate interest in handling your personal data.

3. How We Use Personal Information

We use this/your Personal Information to:

  1. Communicate with you and others as part of our business.
  2. Send you important information regarding changes to our policies, other terms and conditions, the electronic services and other administrative information.
  3. Make decisions about whether to provide insurance; provide insurance and assistance services.
  4. Assess your eligibility for payment plans and process your premium and other payments.
  5. Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
  6. Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
  7. 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.
  8. Personalise your experience via electronic services by presenting information and advertisements tailored to you.
  9. Identify you to anyone to whom you send messages through electronic services.
  10. 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.
  11. Facilitate social media sharing functionality.
  12. 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.
  13. 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).
  14. 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

Brokersure Ltd may make Personal Information available to:

  1. Our group companies: Brokersure Ltd is a subsidiary of Brokersure Group Ltd; we may share your personal data with certain areas of our group companies, but only for the purposes set out in this Privacy Policy. Brokersure Ltd remains responsible for the management and security of jointly used Personal Information. Access to Personal Information within Brokersure Ltd, and our group of companies, is restricted to those individuals who have a need to access the information for our business purposes.
  2. Other insurance and distribution parties: In the course of marketing and providing insurance and processing claims, Brokersure Ltd 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.
  3. 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.
  4. Recipients of your social sharing activity: Your friends associated with your social media account, other website users and your social media account provider, in connection with your social sharing activity, such as if you connect your social media account provided by another social media service provider to your electronic services account or log into your account from another social media account. By connecting your electronic services account and your other social media account you authorise us to share information with the provider of your other social media account and you understand that the use of the information we share will be governed by the other service provider's social media website's privacy policy. If you do not want your Personal Information shared with other users or with your other social media account provider, please do not connect your other social media account with electronic services account and do not participate in social sharing on the electronic services.
  5. By purchasing a policy that includes the possibility of data transfer outside of the European Economic Area (EEA) you consent to us transferring your information as required.

  6. Governmental authorities and third parties involved in court action: Brokersure Ltd 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.
  7. 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.
  8. Personal Information may also be shared by you, on message boards, chat, profile pages and blogs, and other 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 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 electronic services.

6. Security

Brokersure Ltd 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 Brokersure Ltd 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

Brokersure Ltd takes reasonable steps to ensure that the Personal Information we process is reliable for its intended use, and as accurate and complete as is necessary to carry out the purposes described in this Privacy Policy. Brokersure Ltd will retain your information for a period of time which is deemed necessary to fulfil the purpose of the policy such as claims. This period will normally be 7 years from the date of expiry of the policy however this may be extended for certain classes of business.

8. Personal Information of Other Individuals

If you provide Personal Information to Brokersure Ltd regarding other individuals, you agree: (a) to inform the individual about the content of this Privacy Policy; and (b) to obtain any legally-required consent for the collection, use, disclosure, and transfer (including cross-border transfer) of Personal Information about the individual in accordance with this Privacy Policy.

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 change your marketing preference including withdrawing permissions, you can also contact us by email enquiries@brokersure.com or by writing to: Marketing Preference Team, Brokersure Ltd, Digital House, Threshelfords Business Park, Feering, Colchester, Essex. CO5 9SE

  1. Receiving email messages and text messages from us: If you no longer want to receive marketing-related emails or text messages from Brokersure Ltd on an ongoing basis, you may change your previously selected preferences by clicking on the link to "unsubscribe" provided in each message or by contacting us at the above addresses.
  2. Receiving telephone communications and postal mail from us: If you no longer want to receive mobile messages, telephone communications or postal mail, email from Brokersure Ltd on an ongoing basis, you may change your previously selected preferences by contacting us at the above addresses.
  3. 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 change your previously selected preferences by contacting us at the above addresses.
  4. 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 change your previously selected preferences by contacting us at the above addresses.

We aim to comply with your request(s) within a reasonable time period. Please note we have a regulatory responsibility to advise you of the expiry of any annual policy irrespective of any requested ‘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 electronic services and other Services "Other Information" is any information that does not reveal your specific identity, such as:

  1. Browser and electronic device information;
  2. Information collected through cookies, pixel tags and other technologies;
  3. Demographic information and other information provided by you; and
  4. Aggregated information

Other Information We Collect

We and our third-party service providers may collect Other Information in a variety of ways, including:

  1. 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 electronic services (such as the App) you are using. We use this information to ensure that the electronic services function properly.
  2. Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to recognize your computer and to collect information such as internet browser type, time spent using the electronic services, pages visited, language preferences and relevant country website. We may use the information for security purposes, to facilitate navigation, to display information more effectively, to Personalise your experience while using the electronic services, or to gather statistical information about the usage of the electronic services. Cookies further allow us to present to you the advertisements or offers that are most likely to appeal to you. We may also use cookies to track your responses to our advertisements and we may use cookies or other files to track your use of other websites.

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

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the electronic services link. The inclusion of a link on the electronic services does not imply endorsement of the linked site or service by us or by our group companies. Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the information security practices) of other organisations, such as Facebook®, Twitter®, Apple®, Google®, Microsoft®, RIM/Blackberry® or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or electronic device manufacturer, including any Personal Information you disclose to other organisations through or in connection with the electronic services.

13. Use of Electronic Services by Minors

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 Electronic Services.

14. Changes to This Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.