Introduction
Introduction
ERGO Travel Insurance Services Ltd. (ERGO TIS) manages and administers your personal data when you purchase an
insurance policy from us. ERGO Travel Insurance Services Ltd is collectively referred to in this Privacy Policy
as
"we", "us" or "our".
Unless otherwise indicated in your Policy Wording, ERGO Travel Insurance Services Ltd. is the controller of your
personal data and is responsible for your personal data.
This Privacy Policy is designed to help you to understand how we process your personal data. This applies
whether
you are a customer of ERGO TIS or someone involved in the insurance or claims process (e.g., a claimant or
injured
party). We underwrite your policy on behalf of Great Lakes Insurance UK Limited (GLUK).
You may have purchased your insurance through an intermediary, such as an insurance broker or another party
authorized by us. We may also collect your data to assess claims or evaluate damages. During the insurance
lifecycle
or claims process, we may share your data with other insurance participants. Some of these entities may not
interact
with you directly.
For more information about these processors, contact the intermediary through which you purchased your policy.
Our contact details
| Company Information |
Name: ERGO Travel Insurance Services Ltd
Address: 1 Fen Court, Fenchurch Avenue, London, England, EC3M 5BN
Phone Number: 01403 788513
E-mail: contact@ergo-travel.co.uk
Website: www.ergotravelinsurance.co.uk
|
| Data Protection Officer for ERGO Travel Insurance Services Ltd |
Data Protection Officer
Address: Afon House, Worthing Road, Horsham, RH12 1TL
E-mail: dataprotectionofficer@ergo-travel.co.uk
|
Data Controllers and Processors
ERGO TIS acts as the Data Controller for the personal data you provide, directly or via our Data Processors. We
oversee the management, processing, and safeguarding of your personal information.
Great Lakes Insurance UK Limited also acts as a Data Controller for certain personal data we collect. GLUK is
responsible for safeguarding this data in accordance with its privacy practices. For more information about how
GLUK
uses your personal data and to get its contact information, please visit: https://www.munichre.com/Great-Lakes-Insurance-UK-Information-Notice
Our trusted partners process your data on behalf of ERGO TIS for specific purposes, such as generating policy
quotes
and handling claims. Some may also act as independent Data Controllers for other purposes as outlined in their
privacy notices. For more details, please review the Privacy Policy of our partners which link is available in
your
Policy Wording.
What types of personal data do we
collect?
We currently collect and process the following types of personal data:
- Individual information: Name, address, title, date of birth, nationality, residence, family details,
and
their relationship to you.
- Policy information: Information about the quotes and insurance policies you have applied for or taken
out.
- Financial Information: Premiums and claims paid on your policies. Bank account or payment card
details.
Income and other financial information.
- Statutory and anti-fraud information: Sanctions and information from anti-fraud databases concerning
you.
- Claim information: Information about previous and current claims.
- Individual and claim information: Gender and health information. Medical reports. Criminal records and convictions.
- Statutory and anti-fraud information: Criminal records and convictions.
- Personal data concerning health: Medical history and medical data.
How We Get the Personal
Information and Why We Have It
Most of the personal information we process is provided directly by you when purchasing an insurance product
with
us. Additionally, we may collect your personal data through our processors, who act on our behalf (e.g. claims
handlers or assistance companies).
What
are our purposes and legal basis for processing your personal data?
We process your personal data based on the following lawful bases:
- Consent: Where applicable, we rely on your explicit consent to process your personal data.
- Contractual Necessity: We process personal data when necessary to perform the insurance contract.
- Legal Obligations: Where required for compliance with legal obligations.
- Legitimate Interests: We process data in our legitimate interests, such as managing claims and
improving
customer service, provided these interests are not overridden by your rights and freedoms.
- For special categories of personal data required for assessing or processing claims (e.g., health data),
ERGO
TIS relies on the Insurance condition under the Data Protection Act 2018, Schedule 1, Part 2,
paragraph
20. This provision allows us to process necessary data in substantial public interest for insurance
purposes,
even without explicit consent, where relying on consent may disrupt the effective delivery of insurance
services.
The details of how we collect your personal data, the purposes of processing and our lawful basis for processing are detailed below:
|
Categories of personal data
|
Where the personal data may come from
|
Purposes of processing
|
Lawful basis of processing
|
|
Individual Information
|
- Directly from the insured
- Insurance intermediaries or other insurance market participants
- Insured’s family
|
- Setting you up as a client including checks for potential fraud, sanctions, credit, and anti-money laundering
- Managing you as a client including underwriting, evaluating and pricing the risks to be insured, and calculating and validating the appropriate premium for your policy
- The automated and non-automated provision of Insurance to insured, as set out on the insurance contract
- Statistical analysis.
|
- Performance of our contract with you
- Consent
- Legitimate interest from agents, brokers, insurance companies, and other interested parties.
|
|
Policy Information
|
- Directly from the insured
- Insurance intermediaries or other insurance market participants
- Insured’s family
- Your employer
|
- Managing you as a client including underwriting, evaluating and pricing of the risks to be insured and calculating and validating the appropriate premium for your policy
- The automated and non-automated provision of Insurance to insured, as set out on the insurance contract
- Statistical analysis
|
- Performance of our contract with you
- Consent
- Legitimate interest from agents, brokers, insurance companies, and other interested parties
|
|
Financial Information
|
- Directly from the insured
- Insurance intermediaries or other insurance market participants
- Insured’s family
- Your employer
|
- Managing you as a client including underwriting, evaluating and pricing of the risks to be insured and calculating and validating the appropriate premium for your policy
- The automated and non-automated provision of Insurance to insured, as set out on the insurance contract
- Statistical analysis
|
- Performance of our contract with you
- Consent
- Legitimate interest from agents, brokers, insurance companies and other interested parties
|
|
Statutory and anti-fraud information
|
- Directly from the insured
- Insurance intermediaries or other insurance market participants
- Insured’s family
- Your employer
- Anti-fraud databases
- Sanctions lists
|
- Setting you up as a client including checks for possible fraud, sanctions, credit and anti-money laundering
- Managing you as a client including underwriting, evaluating and pricing the risks to be insured and calculating, validating and collecting any appropriate premium
|
- Performance of our contract with you
- Compliance with a legal obligation
- Processing is necessary for the defence of legal claims
|
|
Claim Information
|
- Directly from the insured
- Insurance intermediaries or other insurance market participants
- Insured’s family
- Your employer
- Anti-fraud databases, claimants, defendants, witnesses, experts inc. medical experts, loss adjustors, solicitors and claims handlers
|
- Managing insurance and reinsurance claims
- Defending or prosecuting legal claims
- Investigating or prosecuting fraud
- Statistical analysis
|
- Performance of our contract with you
- Compliance with a legal obligation
- Consent
- Processing is necessary for the defence of legal claims
- Legitimate interest from agents, brokers, insurance companies and other interested parties
|
|
Individual and claim Information
|
- Directly from the insured
- Insurance intermediaries or other insurance market participants
- Insured’s family
|
- Setting you up or managing you as a client. Evaluating and pricing the risks to be insured and calculating and validating any appropriate premium
- Claims administration
- The automated and non-automated provision of Insurance to insured, as set out on the insurance contract
- Statistical analysis
|
- Performance of the insurance contract with you
- Consent
- Processing is necessary for the defence of legal claims
- the insurance condition under the Data Protection Act 2018, Schedule 1, Part 2, paragraph 20.
|
|
Personal Data concerning health
|
- Directly from the insured
- Insurance intermediaries or other insurance market participants
- Insured’s family
|
- The automated and non-automated provision of Insurance to insured, as set out on the insurance contract
- Evaluating and pricing the risks to be insured and calculating and validating any appropriate premium
|
- Insurance condition under the Data Protection Act 2018, Schedule 1, Part 2, paragraph 20.
- Explicit consent (specific cases)
|
Who is your personal data shared with?
The following are data controllers that we share your personal data with:
- Great Lakes Insurance UK Limited and other companies within ERGO Group.
- Agents that sell insurance products on our behalf.
- Brokers that have advised our insurance products to you.
- Government Agencies.
- Legal advisers.
The following are processors that we disclose your personal data to:
- Third Parties providing services for Banking.
- Claims Handling (Davies Group Limited, Euro-Center Holding SE, Insurance Administration Services Ltd, Gallagher Bassett International Limited, Insurance Factory Limited and Taurus Insurance Services Limited and Trent-Services (Administration) Limited).
- Assistance Providers (Euro-Center Holding SE, Global Excel Management Inc, Mayday Assistance Limited, Air Doctor Ltd and OnlineVet 247 UK Ltd).
- Insurance Administration.
- IT Services.
Please contact the Data Protection Officer (dataprotectionofficer@ergo-travel.co.uk.) if you require further information on who your data is shared with.
You can find more information concerning the recipients of your personal data in your policy wording and the privacy policy of the intermediary that you purchased your policy from.
How long do we keep your personal
data?
Your personal data will only be kept for as long as it is necessary for the purpose it was collected for. We
normally keep your personal data for 7 years after the end of the insurance agreement between us and you. We can
keep your personal data for a longer time, for example, for claims and court proceedings.
Please contact the Data Protection Officer (dataprotectionofficer@ergo-travel.co.uk.) if you require further information concerning the retention period of your personal data.
Artificial Intelligence and
Automated Decision-Making
ERGO TIS utilises AI technology provided by CourtCorrect Ltd (CourtCorrect) to enhance the management and
resolution
of complaints. CourtCorrect is designed to analyse complaints data, identify key trends, and assist in
generating
appropriate responses, all aimed at improving efficiency and response times. It is important to note that this
does
not constitute automated decision-making. We ensure that human intervention is part of every decision-making
process, with AI being used solely as a tool to support and streamline complaints handling.
The use of CourtCorrect is based on our legitimate interests in providing a high-quality service to our
customers,
as well as in substantial public interest (Insurance condition) for processing special categories of personal
data
where relevant. We do not use customer data to develop or train AI models. CourtCorrect acts as a
processor
on ERGO TIS behalf and handles personal data strictly on our behalf and in accordance with our instructions. For
further details on CourtCorrect's privacy practices, please refer to their privacy policy: https://www.courtcorrect.com/privacy-policy
As part of processing your personal data, decisions may be made automatically, for example, to calculate premiums for pre-existing medical cover.
When booking we use your data to make sure you are who you say you are. If your data is inconsistent with your previous submissions; or you appear to have, on purpose, hidden your true identity we will prevent you from booking with us.
To calculate premiums for pre-existing medical cover. We use a system provided by Verisk Risk Rating Limited to calculate a risk score, which is used across the industry by other insurance providers. Verisk will make some automated decisions about you which will be based on comparing you with other people.
You have a right to challenge these automated systems. For decisions that are fully automated, you have the following rights:
- Right to Explanation: You can request an explanation of how the automated decision was made and the underlying logic.
- Right to Object: If you wish to challenge an automated decision, you may contact us to express your views or ask for human intervention.
- Right to Obtain Human Review: Where applicable, you can request that a human review the decision to ensure fairness and accuracy.
If you have concerns or questions about how AI or Automated Decision-Making affects the processing of your personal data, you may contact our Data Protection Officer for further assistance.
What are your rights?
Under data protection law, you have rights including:
- Your right of access - You have the right to ask us for copies of your personal information.
- Your right to rectification - You have the right to ask us to rectify personal information you think
is
inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure - You have the right to ask us to erase your personal information in certain
circumstances.
- Your right to restriction of processing - You have the right to ask us to restrict the processing of
your
personal information in certain circumstances.
- Your right to object to processing - You have the right to object to the processing of your personal
information in certain circumstances.
- Your right to data portability - You have the right to ask that we transfer the personal information
you
gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. We can extend it up to 2 months.
Please contact the Data Protection Officer (dataprotectionofficer@ergo-travel.co.uk.) if you wish to make a request.
Protection of Your Information
Your privacy is important to us, and we follow strict security and organizational procedures in the processing,
storage, destruction, and disclosure of your information. This is to prevent unauthorized access or loss of your
information.
Transfer of Data
We will not transfer your personal data outside the UK or EEA where there is not an adequate level of data
protection.
Your personal data may be disclosed to companies within our Group or to Service Providers outside the UK or EEA. However, we ensure that there is an adequate level of data protection in place and adhered to by these parties.
You can find the details about any other party we have shared your personal data with by contacting the Data Protection Officer at the address provided at the top of this information notice, in your policy wording, and in the privacy policy of the intermediary that you purchased your policy from.
How to Complain
If you have any concerns about our use of your personal information, you may contact our Data Protection Officer
at
the aforementioned address, or via the e-mail address dataprotectionofficer@ergo-travel.co.uk.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO's address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk