Privacy Policy
True Traveller ("we", "us", "our"), means The True Traveller Limited, a company registered in England and Wales. Registered number: 07368275, and True Traveller s.r.o., a company registered in the Czech Republic. Registered number: 118 79 084.
Our webserver is PCI Compliant, which means it has undergone rigorous testing to ensure it meets the high standards of The Payment Card Industry Data Security Standard (PCI DSS) to ensure that we process and transmit your card details securely.
We use Ecommpay as our payment partner, and they process your payments on our website. We do not store any of your card details on any of our systems.
Who is the data controller?
A data controller is the individual or legal person who controls the use of the data and is responsible for keeping it safe. The laws apply to personal data in both paper and electronic files. True Traveller is the data controller as defined by relevant data protection laws and regulations.
We are registered with the Information Commissioners Office in the United Kingdom on the Data Protection Register, and our registration number is Z2475562.
What personal data we collect
Depending on the type of insurance product or service we provide to you, we will collect and process various types of personal data about you whether you apply for your insurance online or by phone to our call centre:
surname, first name
address
place of residence
date of birth (which may be required for fraud detection purposes)
gender
telephone numbers
email address
your location from the IP address of your computer
credit/debit card numbers are collected and transmitted to Ecommpay but are not stored or retained.
Recording of telephone calls
We may record your telephone calls you make to our offices to:
check for mistakes
train staff
compliance purposes
We do this in the interests of offering a good service. If you object to this, you will need to end the call when you are told that calls may be recorded. If any credit card number are taken over the telephone, our consultant will advise you that the call recording has been stopped, and then you will be advised that the call recording has been re-started once we have your card details.
Online Chat
During office hours, on our website we operate an online chat system provided by livechat.com (opens in a new window - please note that we are not responsible for the content of external websites). This is purely to answer questions you may have about our insurance, but we cannot quote premiums or take payment over this medium. We do collect your name and email address, but this is only taken to enable us to send you an email transcript of the conversation.
What we do with your personal data?
We collect and use the personal data that you provide to us and that we receive about you (as explained below) for a number of purposes. We provide more information in the following table:
Purpose
|
Do we need your express consent?
|
the administration of products (for example, providing quotes, sending details of cover, handling claims)
|
no
|
to administer debt recoveries
|
no
|
fraud prevention and detection
|
no
|
to meet any legal obligations (for example, tax, accounting and administrative obligations)
|
no
|
to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers
|
no
|
to enhance the security of our networks and information systems
|
no
|
to better understand how customers interact with our websites
|
no
|
to determine the effectiveness of our promotional campaigns and our advertising
|
no
|
We will process personal data we receive about you from third parties such as brokers and business partners, other insurers and fraud prevention agencies.
We will process your personal data where it is necessary for us to comply with our contractual obligations to you, or where we need to take pre-contractual steps at your request.
We will process your personal data where necessary for the purposes of our legitimate interests. “Legitimate interests” means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. For example, we may process your information to protect you against fraud when transacting on our website and to ensure that our websites and systems are secure. When we process your personal information for our legitimate interests, we make sure that we consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests –we will not use your personal data where our interests are overridden by the impact on you (unless we are required or permitted by law).
Special category data is personal data which is regarded as more sensitive and so needs greater protection, such as medical records. In the event of a medical emergency, we may need to share this information with selected third parties such as doctors and hospitals. In such circumstances, where necessary to protect your health, we will process and share such data either with your explicit consent or, where we this is not possible, we will do so to protect your vital interests.
We will need your personal data and use it for the purposes described above if you would like to buy our products and services. If you do not wish to provide this to us, we may not be able to provide the products and services to you.
Who will have access to your personal data?
We will ensure that your personal data is processed in a manner that is compatible with the purposes indicated above.
For the reasons stated above, your personal data may be disclosed to the following parties who operate as third-party data controllers depending on the type of policy you have bought from us:
our Underwriter, Inter Partner Assistance S.A., part of the AXA Group
industry governing bodies, regulators, fraud prevention agencies and claims databases, for underwriting and fraud prevention purposes;
our 24-hour Emergency Medical Assistance Service, AXA ASSISTANCE CZ, s.r.o., doctors and other health professionals in the event of a medical emergency; airline companies in the event of repatriation;
our claims service, True Traveller s.r.o. for the settlement of nonemergency claims such as cancellation or baggage claims.
We do not share your personal data with non-affiliated third parties for marketing purposes without your permission.
Finally, we may share your personal data in the following instances:
in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in any insolvency or similar proceedings); and
to meet any legal obligation, including to the Financial Ombudsman Service if you make a complaint about the product or service we have provided to you.
Where will your personal data be processed?
Your personal data may be processed both inside and outside of the European Economic Area (EEA) by the parties specified above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose your personal data to parties who are not authorised to receive it.
What are your rights in respect of your personal data?
Where permitted by applicable law or regulation, you have the right to:
access the personal data held about you and to learn the origin of the data, the purposes and ends of the processing, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed;
withdraw your consent at any time where your personal data is processed with your consent;
update or correct your personal data so that it is always accurate;
delete your personal data from our records if it is no longer needed for the purposes indicated above;
restrict the processing of your personal data in certain circumstances, for example where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy;
obtain your personal data in an electronic format for you or for your new insurer; and
file a complaint with us and/or the Information Commissioner’s Office.
You may exercise these rights by contacting us as detailed below.
How can you object to the processing of your personal data?
You have the right to object to us processing your personal data, or tell us to stop processing it. Once you have informed us of this request, we shall no longer process your personal data unless permitted by applicable laws and regulations.
You may exercise this right in the same manner as for your other rights indicated above.
How long do we keep your personal data?
We will retain your personal data for a maximum of seven years from the date the insurance relationship ends. If we can do so we will delete or anonymise certain areas of your personal data as soon as that information is no longer required for the purposes for which it was obtained.
Automated decision making, including profiling
We may use automated decision making, including profiling, to assess insurance risks, detect fraud, and administer your policy. This helps us to decide whether to offer the insurance and determine prices.
For example, when you buy a travel insurance product, we carry out automated decision making. We may accept or reject a potential policyholder for cover based on their age. We do not offer insurance for customers aged 66 or more. If accepted, the automated calculation of a person’s age may be used to calculate the premium payable.
If you have any concerns regarding the decision reached, please let us know at the contact details set out below and we will arrange for a person to check the accuracy of the result.
Links to other websites
Our website may contain links to other websites run by other organisations which we do not control. This policy does not apply to those other websites and Apps‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and Apps (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.
In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third party website.
How can you contact us?
If you have any queries about how we use your personal data, you can contact us as follows:
By post: Data Protection Officer, The True Traveller, 6 Drakes Courtyard, Kilburn High Road, London NW6 7JR.
By telephone: 020 3822 0200
By email: [email protected]
We will need details of your name, email address, policy number, and purpose of your request.
How often do we update this privacy notice?
We regularly review this privacy notice. This privacy notice was last updated in May 2024.