• Information that is automatically collected for example cookies when you visit one of our websites
• Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the product, service and/or claims arising out of the product or quotation you have requested or to comply with our legal obligations
• Information you may provide us about other people e.g. joint applicants or beneficiaries for products you have with us
• Information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent, guardian, school or other person/group for the purposes of a group travel policy on their behalf. In these cases, we will normally only collect and use only the information required to identify the child (such as their name, age, gender) however medical information may be held but only where required in performance of an insurance quotation or policy.
What are cookies?
• Persistent cookies - these stay valid, and will work until their expiry date (unless you delete them before they expire)
• Session cookies - these expire when you close your web browser
Fogg Travel Insurance operates various different platforms, websites and microsites, where we use, store and process your information in a way that is specific to each application.
Where we collect your information
We may collect your personal information directly from you, from a variety of sources, including:
• an application form for a product or service
• phone conversations with us
• emails or letters you send to us
• our online services such as websites, social media and mobile device applications ('Apps')
We authorise certain companies, including tour operators, travel agents to offer and sell our products. If you have requested a quotation or purchased an insurance cover via one of these sources, the information we collect and use will most likely have been provided by them on your behalf. We may also collect personal information on you from places such as commercially or publicly available sources
What we collect and use your information for
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:
• you have given us your permission [consent] to send you information about products and services offered by other parts of Fogg Travel Insurance
• it’s necessary to provide the product or service you have requested e.g. if you request one of our products or quotation, we will require some personal information including your name, address, date of birth, and may include bank account details
• it’s necessary for us to meet our legal or regulatory obligations, tell you about changes to Terms and Conditions or for the detection and prevention of fraud
• it’s in the legitimate interests of Fogg Travel Insurance e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your insurance product
• where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services
• it’s in the legitimate interests of a third party
• If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products.
We sometimes use systems to make automated decisions based on personal information we have - or are allowed to collect and use from others – about you. These automated decisions can affect the products, services or features we offer you now or in the future. We use automated decisions in the following ways:
• Assessing on Insurer’s behalf the insurance risk for the type of cover requested.
• Tailoring products and services
• Designing and enhancing our online services to help meet your requirements
Who we may share your information with
We may share your information with third parties for the reasons outlined in 'What we collect and use your information for.'
These third parties include:
• Insurers and their authorised suppliers for the purposes of fulfilment of insurance quotations, contracts and/or renewal.
• Supervisory Authorities e.g. the Financial Conduct Authority (FCA), The Financial Ombudsman Service, the Information Commissioner’s Office for the UK (the ICO)
• Law enforcement, credit and identity check agencies for the prevention and detection of crime
Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure. We will never sell your details to someone else.
Where your information is processed
The majority of your information is processed in the UK and European Economic Area (EEA).
However Insurers may process information outside of the EEA. If and when your information is being processed outside of the EEA, the Insurers will take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws.
How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and undertake regular training.
Our security controls are in accordance with industry standards and good practice; providing an environment that effectively manages risks to the confidentiality, integrity and availability of your information.
How long we retain your information
We will keep your personal information only where it is necessary to provide you with our products or services while you are a customer.
We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.
Your individual rights
You have several rights in relation to how Fogg Travel Insurance uses your information. They are:
Right to be informed
Right of access
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).
Right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for Fogg Travel Insurance to continue to have it.
Right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your insurance to another insurance provider.
Right to object
You can object to Fogg Travel Insurance processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.
Rights related to automatic decision making including profiling
You have the right to ask Fogg Travel Insurance to:
• give you information about its processing of your personal information
• request human intervention or challenge a decision where processing is done solely by automated processes
• carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.
How to contact us
FAO Data Protection Officer
Fogg Travel Insurance Services Limited,
Crow Hill Drive,
Mansfield, Nottinghamshire NG19 7AE
How to make a complaint
If you are still unhappy, you can complain to our Supervisory Authority. Their contact details are: