Introduction

Welcome to Postcard’s privacy notice. Postcard is a trading brand name of Travel Insurance Facilities Plc (tifgroup), which is a UK acting branch for White Horse Ireland dac (the Insurer).

tifgroup manages and administrates your data to perform its obligations under your contract when you purchase a travel insurance policy with Postcard. tifgroup is the controller and responsible for your personal data collectively referred to as tifgroup, “we”, “us” or “our” in this privacy notice.

tifgroup respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to 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.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

• Important Information and who we are
• The data we collect about you and how the law protects you.
• How is your personal data collected?
• How we use your personal data?
• Disclosures of your personal data
• Automated decision making and profiling
• Data security
• Data retention
• Your legal rights
• Glossary

1. Important Information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how tifgroup collects and processes your personal data through your use of this website and purchasing travel insurance with us, including sign up to our newsletter, purchase of a travel insurance product or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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. This privacy notice supplements the other notices and it not intended to override them.

Controller

tifgroup is made up of different brands and Postcard is one of them. In most cases, tifgroup will be the controller of your data and will do its utmost to protect the data provided by you. Please read the privacy policy to understand how your personal data is being processed. We will let you know how we use your data. tifgroup is the controller and responsible for this website.

Contact details:

Our full details are:

Full name of legal entity: Travel Insurance Facilities PLC

Title: Data Protection Officer 

Email address: compliance@tifgroup.co.uk

Postal address: 1 Tower View, Kings Hill, West Malling, Kent, ME19 4UY

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 issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

This version was last updated on 21^st May 2018 and historic are archived and can be obtained by contacting us. 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 notice of every website you visit.

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).

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

• 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, postal address, email address and telephone numbers.
• Financial Data includes bank account and payment card details to purchase a policy. Financial data will be encrypted accordingly.
• 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 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 preferences.
• Health and Medical Information includes medical history obtained from you, GP records (with your express consent), medical reports from hospitals abroad and other medical information required to fulfil our obligation as your travel insurer.

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 is not 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 privacy notice.

We do collect Special Categories of Personal Data about you. This is subject to your health and medical data in order to calculate your premium and to process your purchase with tifgroup. This will be contained in three of our stages:

• Point of Sale (when you contact the call centre and/or use our online customer journey) – we will obtain your medical history.
• Emergency Medical Assistance – current medical situation and potentially revisiting medical history, medical reports, medical advice in relation to you and your travel companion.
• Claims – document to evident your claim such as a copy of your passport or driving licence, share details to fraud agencies or contacting your GP with consent.

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 purchasing travel insurance products either through our contact centre or through our website online, including correspondence with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:

• Create an account on our websites;
• Subscribe to our service or publications;
• Request marketing to be sent to you;
• Enter a competition, promotion or survey; or
• Give us some feedback.

Automated technologies or interactions.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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

• Analytics providers such as Google based outside the EU.
• Advertising networks such as Affiliates based in the UK.
• Search information providers

Identity and Contact Data from data brokers or aggregators within the EU.

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

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 our obligations within your 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 obtain consent to send any marketing materials.
• Where we need to comply with a legal or regulatory obligation.

Click https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/ to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not 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.

Purpose for which we will use your personal data

We have set out below, in a table format, 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.  On the basis we use your personal data under the grounds of Legitimate Interests we will compile and record a Legitimate Interest Assessment to protect your rights and freedoms.

Note that 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 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	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or for you to receive a quote	(a)Identity (b Contact (cHealth and Medical Information (d)Financial	(a)Performance of a contract with you
To process and deliver your product and services including: (a)Collecting medical data (b)Providing medical assistance abroad (c)Claims handling (d)Manage payments, fees and charges	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c ) Consent
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 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 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
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	(a)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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	(a)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 or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a)Necessary for our legitimate interests (to develop our products/services and grow our business)

Change of purpose

We will only use your personal data for the purposes for which we collected it, 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 as to 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 notify you 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.

5. 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 in set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary, which tifgroup will be in a legal binding contract.

• Third parties to whom we decide to go into business with, for example sell travel insurance on tifgroup’s behalf, transfer, or merge parts of our business or our assets. 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 privacy notice.

• If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or

• From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it.

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 permit them to process your personal data for specified purposes and in accordance with our instructions.

At times, we can be joint controllers, processors or controllers for different personal data when we merge into business with other organisations. In order to find out more detail, click on the privacy policy of where you purchase your insurance product from to be clear of the parties involved. If you have any questions in relation to who is in control of your data, please contact us.

6. Automated decision making and profiling

Automated decision-making is the making of a decision about you based solely on automated means without any human involvement. This occurs when we conduct a medical screening at the beginning of your customer journey either online or through our call centre. The system is pre-programmed algorithms that assist in calculating your premiums.

You have the right to object to profiling and automated decision-making as set out below. In these circumstances, you have the right to request an adviser of tifgroup to review the automated decision, as part of this process you also have the option to let tifgroup know the reason for your objection and ask us for a reconsideration of the decision. You can contact tifgroup to exercise these rights by contacting us.

By law, we must tell you when we rely on an automated decision-making process, (making a decision using technology, without any person being involved). This occurs when we conduct a medical screening at the beginning of your customer journey either online or through our call centre. The system is pre-programmed algorithms that assist in calculating your premiums.  We are also required to tell you when we use profiling (automated processing of your information to help us evaluate certain things about you, for example, your personal preferences and your interests) for example:

• Underwriters: our underwriters will assess risk, calculating premiums and what kind of cover we can offer. The type of data we will process are Identity Data and information about your trip for us to understand the likelihood of a certain event that may occur. With the results, we will determine the premiums and extent of cover.

• Medical screening: we use a risk rating tool which determines the answers given to the relevant questions that we deem relevant to purchase insurance. This permits us to understand the risk of the medical condition declared against factors such as the destination chosen, duration of the holiday, and type of trip you have chosen to go on.

When tifgroup makes a decision about you using automated processing which has a significant impact on you, we will let you know as part of your customer journey. You then have 21 days to ask us to reconsider our decision or to make a new decision using human intervention rather than automated processing. If we receive a request from you, within 21 days of receiving your request, we will:

• consider the request, including any information you have provided that is relevant to it;
• meet your request; and
• let you know in writing what we have done to meet your request, and the outcome.

7. 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.

Our IT estates are protected by enterprise level hardware based firewall systems, with scans being performed regularly to ensure that any vulnerabilities are quickly found and patched. Annual penetration tests are performed by external parties. All services have auto fail-over points and redundant hardware, with complete backups performed as a minimum daily. Access to systems is severely restricted to specific individuals, whose access is monitored and audited. Access levels are granted based on user role and changes are subject to strict pre-approval processes. All client data encrypted at rest and is stored within UK based data centres, within tifgroup controlled infrastructure. Our applications utilise Transport Layer Security (TLS) & Secure Socket Layer (SSL) encryption (also known as HTTPS) for all transmitted data. We also protect applications with encrypted passwords.

We have put in place procedures 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.

8. Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by contacting us.

After your policy expires with us, we may keep your data for up to 7 years.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• 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 these rights set out above, please contact us

It is our standard practice to only send transcripts of telephone recordings to you or any third party unless it is deemed absolutely necessary to disclose the recordings.

No fee usually required

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 may refuse to comply with your request in these 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 that 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 will notify you and keep you updated.

10. 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 do not 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 is 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

External Third Parties:

• Service providers acting as processors based in Ireland who provide their database to hold all our data;
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
• Fraud prevention agencies acting as processor to prevent any fraud activities that may occur;
• Market researchers acting as processor to provide the best customer experience;
• Price comparison websites and similar companies that offer ways to research and apply for financial products and services, such aggregators;
• Charities acting as processors to provide customers with gift aid;
• Affiliates acting as processors that use advertising methods which include organic search engine optimisation (SEO), paid search engine marketing (PPC – Pay Per Click) and e-mail marketing;
• Social Networks;
• Customer Experience tools that shows us your journey of our purchasing travel insurance product for a better understanding to improve your customer experience;
• Competition surveys; and
• Medical doctor apps acting as data controller to provide medical assistance on behalf of tifgroup’s emergency medical assistance.

 

Your Legal Rights

• 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 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. 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. Note, however, that 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.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is 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 override 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 do not 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 it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have 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 are relying on consent to process your personal data. However, this will not 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 will advise you if this is the case at the time you withdraw your consent.