Privacy Statement

ERGO WEBSITE – PRIVACY POLICY

ERGO Travel Insurance
Services Ltd – Privacy Policy

Last update May 2024

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 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 therefore is responsible for your personal data.

This Privacy Policy is designed to help you, as a customer of ERGO Travel Insurance Services Ltd or as a person concerned in connection with the insurance or settlement of claims (for example claimant, injured party, etc.), to understand how we process your personal data. You are a customer of ERGO Travel Insurance Services Ltd and we are the underwriter on behalf Great Lakes Insurance UK Limited of your policy.

However, you may have purchased your insurance through an intermediary, e.g. through an insurance broker or through an intermediary that we have authorised to issue a policy on our behalf. Alternatively, we may need your information to check if an insurance claim has occurred and how much the damage is.

The insurance lifecycle respectively claims settlements may involve the sharing of your personal data with other insurance market participants, some of which, you may not have direct contact with. You can find out more information about these processors by contacting the intermediary that you purchased your policy from.

Our contact details

Company Information

Name: ERGO Travel Insurance Services Ltd

Address: Afon House, Worthing Road, Horsham,
West Sussex, RH12 1TL, United Kingdom

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,
West Sussex, RH12 1TL, United Kingdom

E-mail: dataprotectionofficer@ergo-travel.co.uk.

The type of personal information 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 to us directly by you at the time to purchase an insurance product with us.

We also collect your personal data through our processors who are acting on our behalf.

The details of how we collect your personal data, 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 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 insureds, 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 insureds, 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 insureds, 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 insureds, 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
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 insureds, as set out on the insurance contract Evaluating and pricing the risks to be insured and calculating and validating any appropriate premium	Performance of the insurance contract with you Consent

Who your data is shared with

The following are data controllers that we may disclose your personal data to:

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 data processors that we may disclose your personal data to (subject to the product purchased):

Third Parties providing services for Banking.
Claims Handling (Davies Group Limited, ERGO Insurance Administration Services Ltd, Gallagher Bassett International Limited, Insurance Factory Limited and Taurus Insurance Services Limited).
Assistance Providers (Euro-Center Holding SE, Global Excel Management Inc and Mayday Assistance Limited and Air Doctor Ltd).
Assistance Providers.
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 out 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.

Protection of your information

Your privacy is important to us and we follow strict security and organisational procedures in the processing, storage, destruction and disclosure of your information. This is to prevent unauthorised access or loss of your information.

Use of your Consent to process Special Categories of Personal Data

In order to provide insurance or to carry out claims settlements, in certain circumstances, we may need to process special categories of personal data, such as medical records or criminal conviction data.

We follow the lawful basis of the performance of the insurance contract and explicit consent. If explicit consent is used, you may have given your explicit consent directly to us or to the insurer that you purchased your policy from.

As far as claim settlement is concerned, the legal basis is also the performance of the contract or, if special categories of personal data are required (for example, your health data when examining the claim), we will seek your explicit consent. You may withdraw your consent for us to process your special categories of personal data at any time by contacting the Data Protection Officer (details as above).

However, if you withdraw your consent this will impact on our ability to provide or continue to provide insurance for your insurance policy or pay claims.

Call Monitoring and Recording

For quality control purposes and to audit the evaluation process for the underwriting and pricing of the risks to be insured, we may review copies of telephone recording made with the intermediary that you purchased your policy from.

Data Retention

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 and us and you. We can keep your personal for 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.

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 out 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 the privacy policy of the intermediary that you purchased your policy from.

Automated Decision Making

As part of processing of your personal data, decisions may be made automatically, for example to calculate premiums for pre-existing medical cover.

We will inform you of the existence of automated-decision making in your policy wording.

You have a right to challenge these automated systems.

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 processor to work out a risk score for us. Verisk is the organisation that helps us here and 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.

Use of Artificial Intelligence (AI)

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 data processor, handling personal data strictly on our behalf and in accordance with our instructions.

If you would like more information about how AI is used in complaint management, or if you have any questions about your data, please contact our Data Protection Officer (DPO). For further details on CourtCorrect’s privacy practices, please refer to their privacy policy here.

Your data protection 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 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.

Please contact the Data Protection Officer if you wish to make a request.

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

01403 788 513

Privacy Statement

ERGO UK

Contact

Contact

01403 788 513