Privacy Policy | Petsure

Introduction

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

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

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

Who this privacy policy applies to

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

Purpose of this privacy policy

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

your use of the websites of any of the companies within our group, including any data you may provide through such websites when you make an enquiry about, use or purchase a product or services; and/or
any interaction between you and any of the companies within our group through any other sales, service or claims channels, including where your personal data is provided to us by a third party.

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

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

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

Controller

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

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

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

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

Contact details

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

Email address: [email protected]

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

NN4 7YB

Telephone number: (01604) 552879

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do [contact us] in the first instance.

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

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

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Our Group

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

Staysure a specialist travel insurance intermediary

Avanti Travel Insurance a specialist travel insurance intermediary

PayingTooMuch finding and comparing travel insurance for you

Rock Insurance a specialist travel insurance intermediary

Petsure a specialist pet insurance intermediary

Wapp a specialist travel insurance intermediary

Staysure Ex-Pat travel insurance for ex-pats in Spain, France and Portugal

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

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

Pet insurance

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

Individual Travel Insurance

Identity Data includes name and any former names, username or similar identifier, title, date of birth and gender.
Contact Data includes postal address, email address and telephone numbers.
Damage Data includes information about loss or damage in relation to which you are making a claim under your policy.
Financial Data includes bank account and payment card details.
Health Data includes information about your health including known medical conditions and/or injuries sustained in relation to an insured incident.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
Location Data from your mobile device when you travel under insurance provided by WAPP Limited
Profile Data includes information about your enquiries and/or purchases, the risk insured or to be insured, claims, interests, preferences and feedback.
Usage Data includes information about how you use our websites, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Gadget Insurance

Identity Data includes your name, username or similar identifier, title and job title.
Contact Data includes business address, work email address and work telephone numbers.
Damage Data includes information about loss or damage in relation to which your employer or you as an individual is making a claim under the policy.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
Profile Data includes information about the risk insured or to be insured and claims.

Third Parties

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

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

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

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

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

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

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

If you do not provide personal data when it is requested

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

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

4. HOW WE USE YOUR PERSONAL DATA

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

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

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

Purposes for which we will use your personal data

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

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

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

Pet Insurance

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Performance of a contract with you
To provide you with quotes for insurance products	Identity Contact Profile	A necessary step prior to entry into a contract with you
To arrange, underwrite (including assessing insurance risk) or manage your policy including handling claims in accordance with your policy terms and conditions and financial services regulatory requirements	Identity Contact Profile Damage Health	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to determine whether to offer cover and the terms of such cover, to apply the policy terms and conditions and exercise our rights and obligations) Necessary for an insurance purpose
To pay sums due to you	Identity Financial	Performance of a contract with you
To manage our relationship with you which will include: Notifying you about changes to your policy terms and conditions or this privacy policy	Identity Contact	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact	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 use data analytics to improve our products/services, marketing, customer relationships and experiences	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 recover losses from at-fault third parties	Identity Damage Health	Necessary for our legitimate interests (to safeguard our business and to enforce our legal rights) Necessary for an insurance purpose
To manage relationships with third parties in the insurance sector in relation to your policy	Identity Contact Profile	Necessary for our legitimate interests (to provide you with the best possible service)
To refer your enquiry or application for insurance cover to another entity in our group	Identity Contact Profile	Necessary for our legitimate interests (to grow our business, retain customers and to provide you with the best possible service)
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 and to inform our marketing strategy)
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	Your consent (where these are made by other members of our group) Necessary for our legitimate interests (to develop our products/services and grow our business)
To carry out identity verification, anti-fraud and anti-money laundering checks and other due diligence activity	Identity Contact	Necessary to fulfil a legal obligation In the public interest
To enable the detection and prevention of unlawful acts	Identity Contact Criminal Damage Financial Health Profile Transaction	In the public interest Necessary for an insurance purpose Necessary for our legitimate interests (to safeguard our business from fraud and other criminal activity)
To fulfil regulatory requirements	Identity Contact Damage Profile Transaction Usage	Necessary to fulfil a legal obligation

Individual Travel Insurance

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Performance of a contract with you
To provide you with quotes for insurance products	Identity Contact Health Profile	A necessary step prior to entry into a contract with you Necessary for an insurance purpose
To arrange, underwrite (including assessing insurance risk) or manage your policy including handling claims and complaints in accordance with your policy terms and conditions and financial services regulatory requirements	Identity Contact Profile Damage Health	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to determine whether to offer cover and the terms of such cover, to apply the policy terms and conditions and exercise our rights and obligations) Necessary for reasons of substantial public interest Necessary for an insurance purpose
To determine your location when travelling under a policy provided by WAPP Limited	Location	Your consent
To pay sums due to you	Identity Financial	Performance of a contract with you
To manage our relationship with you which will include: Notifying you about changes to your policy terms and conditions or this privacy policy	Identity Contact	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact	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 use data analytics to improve our products/services, marketing, customer relationships and experiences	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 recover losses from at-fault third parties	Identity Damage Health	Necessary for our legitimate interests (to safeguard our business and to enforce our legal rights) Necessary for an insurance purpose
To manage relationships with third parties in the insurance sector in relation to your policy	Identity Contact Profile	Necessary for our legitimate interests (to provide you with the best possible service)
To refer your enquiry or application for insurance cover to another entity in our group	Identity Contact Profile	Necessary for our legitimate interests (to grow our business, retain customers and to provide you with the best possible service)
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 and to inform our marketing strategy)
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	Your consent (where these are made by other members of our group) Necessary for our legitimate interests (to develop our products/services and grow our business)
To carry out identity verification, anti-fraud and anti-money laundering checks and other due diligence activity	Identity Contact	Necessary to fulfil a legal obligation In the public interest
To enable the detection and prevention of unlawful acts	Identity Contact Criminal Damage Financial Health Profile Transaction	In the public interest Necessary for an insurance purpose Necessary for our legitimate interests (to safeguard our business from fraud and other criminal activity)
To fulfil regulatory requirements	Identity Contact Damage Health Profile Transaction Usage	Necessary to fulfil a legal obligation Necessary for an insurance purpose

Gadget Insurance

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new beneficiary	Identity Contact	Necessary for our legitimate interests (to administer your employer’s insurance policy)
To arrange, underwrite (including assessing insurance risk) or manage your employer’s policy including handling claims in accordance with the policy terms and conditions and financial services regulatory requirements	Identity Contact Profile Damage	Necessary to comply with a legal obligation Necessary for our legitimate interests (to determine whether to provide cover and the terms of such cover, to apply the terms and conditions of the policy and exercise our rights and obligations)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact	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 use data analytics to improve our products/services, marketing, customer relationships and experiences	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 recover losses from at-fault third parties	Identity Damage	Necessary for our legitimate interests (to safeguard our business and to enforce our legal rights)

maximios | January 24, 2025 | Pets|