We respect your privacy and we're committed to protecting your personal data. This policy will tell you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Have a look at the glossary to understand the meaning of some of the terms we've used in this policy.
Important information and who we are
What's this policy for?
This policy aims to give you information on how World Wide Internet Insurance Services Ltd collect and process your personal data when you use our website, including any data you may give us through this website when you buy a policy or service, or take part in a survey.
This website is not intended for use by children and we do not knowingly collect data relating to children for any other purpose than to provide travel insurance services. Data relating to children will not be used for any marketing, analytical or any other reason other than the completion of travel insurance services.
It is important that you read this policy together with any other policy or fair processing notice that we might provide 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 policy supplements the other notices and is not intended to override them.
Who's the controller?
WWIIS Group is made up of different legal entities. This privacy notice is issued on behalf of the WWIIS Group so when we mention “CoverForYou”, "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the WWIIS Group responsible for processing your data. We will let you know which entity will be the controller for your data when you buy a product or service with us. World Wide Internet Insurance Services Ltd is the controller and responsible for this website.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this policy. If you have any questions, including any requests to exercise your legal rights, please contact our DPO using the details below:
E-Mail: dpo@wwiis.com
Write: Data Protection Team, CoverForYou, 1st Floor, 6 Silver Court, Watchmead, Welwyn Garden City, AL7 1LT
If you have any data protection issues, 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 (www.ico.org.uk). However, we would like the chance to understand and deal with your concerns before you approach the ICO - so please contact us first.
Changes to the policy and your duty to inform us of changes
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. Visiting 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.
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 doesn't 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 into several categories:
- 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, delivery address, email address and telephone numbers
- Financial data includes bank account and payment card details
- 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 IP (internet protocol) 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
We 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 isn't 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 policy.
We collect special categories of personal data about you (this includes information about your health) - we need this to provide you with a quote for insurance.
Special categories of personal data will only be used for the specific purpose for which you provide it and to provide the services described in the insurance policy you have entered with us. Make sure you only provide sensitive personal information about other people with their agreement. If you volunteer special categories of personal data during the completion of an online form or application for the provision of our products or services you will be consenting to our processing it for the purpose of providing those policies and services.
If you fail to provide personal data
Where we need to collect personal data by law - or under the terms of a contract we have with you for insurance and services - 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 insurance or services). In this case, we may have to cancel your policy or service you have with us or increase your premium to cover the additional risk. but we will let you know in good time and where necessary ask for your consent.
How is your personal data collected?
We use different methods to collect data from and about you including:
-
Direct interactions. You may give us your identity, contact and financial data by filling in
forms or by getting in touch with us by post, phone, email or otherwise. This includes
personal data you provide when you:
- Apply for our products or services
- Create an account on our website
- Subscribe to our service or publications
- Request marketing to be sent to you
- Enter a promotion or survey
- Give us some feedback
- Automated technologies or 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. Have a look at our cookie policy for more information.
-
Third parties or publicly available sources. We may receive personal data about you from
various third parties and public sources as set out below:
-
Technical data from the following parties:
- Analytics providers such as Google based outside the UK
- Advertising networks such as Doubleclick based outside the UK
- Search information providers such as Bing based outside the UK
- CompareTheMarket.com (view their privacy policy and cookie policy)
- Confused.com (view their privacy policy and cookie policy)
- GoCompare.com (view their privacy policy and cookie policy)
- MoneySuperMarket.com (view their privacy policy and cookie policy)
-
Technical data from the following parties:
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
- 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 or regulatory obligation
Generally we don't 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.
Purposes we'll use your personal data for
Here's 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've also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific reason we're using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
|
To register you as a new customer |
(a) Identity (b) Contact and special categories of personal data |
Performance of a contract of insurance or a contract of services with you |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and communications |
(a) Performance of a contract of insurance or a contract of services with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and communications |
(a) Performance of a contract of insurance or a contract of services with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and communications |
(a) Performance of a contract of insurance or a contract of services with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) 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) (b) Necessary to comply with a legal obligation placed on us by the law, a court, a regulator or any other legal authority |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform and develop our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) 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 and services that may be of interest to you from our group of companies |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Transactional E-Mail and SMS
When you purchase a policy from us there are certain emails that are considered transactional in nature and an important part of our contractual relationship with you, meaning that you will not have the ability to unsubscribe from these emails. You can view more information on this subject here.
Marketing
You can opt-out of any marketing and advertising by following the links on any marketing message sent to you or by contacting us at any time.
Promotional offers from us
You will get marketing communications from us if you have requested information from us or bought a policy or service from us, or if you provided us with your details when you entered a competition or registered for a promotion. We will only do this in each case if you haven't opted out of receiving that marketing.
Third-party marketing
We will get your express permission before we share your personal data with any company outside the WWIIS group of companies for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by 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, warranty registration, product/service experience or other transactions.
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, some parts of our website might become inaccessible or not work properly. For more information about the cookies we use, have a look at our cookie policy.
We will only use your personal data for the purposes we collected it for, 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 of 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 let you know 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. We will not use any special categories of personal data provided for any other purpose than the completion of the provision of services under your insurance policy.
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 above.
- Internal third parties as set out in the table above
- External third parties as set out in the table above
- Third parties we may choose to sell, transfer, or merge parts of our business or our assets to. 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 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 let them process your personal data for specified purposes and in accordance with our instructions.
To assist with fraud prevention and detection we may:
- Share information about you across our group, with other insurers and, where we are entitled to do so under data protection legislation, the police and other law enforcement agencies
- Pass your details to a central insurance application and claims checking system, where it may be checked against information held by that central insurance application and claims checking system and shared with other insurers
-
Check your details with fraud prevention agencies and, if you give us false or inaccurate
information and we suspect fraud, we will record this with the fraud prevention agency and
other organisations may also use and search these records to:
- Help make decisions about credit and credit related services for you and members of your household
- Help make decisions on motor, household, credit, life and other insurance proposals and claims for you and members of your household
- Trace debtors, recover debt, prevent fraud and to manage your insurance policies
- Check your identity to prevent money laundering, unless you give other satisfactory proof of identity
- Undertake credit searches and additional fraud
International transfers
We share your personal data within the WWIIS Group. This will involve transferring your data between the UK and Gibraltar.
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see Information Commissioners Office: Binding corporate rules. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure an essentially equivalent degree of protection is provided 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 by the Information Commissioners Office (ICO) or to countries which, as at 31 December 2020, were covered by a European Commission ‘adequacy decision’.
- Where we use certain service providers, we may use specific contracts approved by the Information Commissioners Office which give personal data the same protection it has in the UK. For further details, see International transfers | ICO.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the UK and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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 procedures in place 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.
Data retention
How long will you use my personal data for?
As a responsible insurance provider, we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers. In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can:
- Request access to your personal data
- Request correction/rectification of your personal data
- Request erasure of your personal data, a right to be forgotten
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
Right to withdraw 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 are allowed and may refuse to comply with your request in these particular 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 a security measure to ensure 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'll notify you and keep you updated.
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 don't 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's 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
Internal third parties
Other companies in the WWIIS Group acting as joint controllers or processors and who are based in the UK and Gibraltar and provide IT and system administration services.
External third parties
We will only use your information for the purposes that you would reasonably anticipate when you buy a travel policy. Where we are making arrangements on your behalf we may need to pass your information to third parties, to conclude those arrangements as you travel worldwide, these third parties may be located outside of the UK. For example, to confirm policy cover when you need to claim whilst travelling, arrange your return to the UK.
As a UK business we have compliance obligations and may occasionally be expected to share information with our regulators and other professional bodies.
To provide our services to you we use:
- Digital communication platform
- Healthcare providers
- Air ambulance services
- Repatriation services
- Funeral directors
- UK coroner
- Ambulance services
- Medical cost containment companies
- Hotels
- Travel agents
- Airlines
- Port agents
- Taxi services
- Cruise ships
- Luggage repatriation services
To comply with business obligations:
- Regulators and other authorities
- Lawyers, bankers, auditors
- Law enforcement agencies
- Cost containment services
- Consular services
- Other insurers
- Investigation services
- Printing services
Your legal rights
You have the right to:
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.
Request correction/rectification 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.
Request erasure of your personal data – right to be forgotten. 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. 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 and will include statutory or regulatory requirements that we're obliged to comply with.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there's 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 overrides your rights and freedoms.
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 don't 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
Request the transfer of your personal data to you or to a third party. We'll provide to you, or a third party you've 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're relying on consent to process your personal data. However, this won't 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'll let you know if this is the case at the time you withdraw your consent.
This version was last updated on 1st February 2021.