Data Protection and Cookies

Travel Insurance is administered on this website by Just Travel Cover, a trading name of Just Insurance Agents Limited (We/Us). If you have been referred to this website by a different company please refer to their privacy policy for details on how your data is used and your rights.

Introduction

We act as your agent and will collect data, including personal information and risk details, solely to enable us to obtain and provide insurance quotations, arrange and administer your insurance. Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are contractual obligation, and for our legitimate business interests as an insurance broker. We will be unable to offer any quotation or insurance if you refuse to provide certain personal data, including health, financial and criminal records data which is collected under the lawful basis of public interest, where these would affect the provision of cover and/or performance of insurance contracts.

For the purposes specified within this privacy statement, we collect and process the following information:

• Personal identifiers, contact details and characteristics (for example, name, address, email address, telephone number)
• Health data
• Criminal records and Financial data – meaning credit/debit card information and other information we need in order to process payments for you.
• Communication Data – meaning records of contact with you e,g system notes, emails and letters.

We regard the lawful and correct handling of personal information by the firm as an essential element in achieving fair treatment of customers and to maintaining confidence between those with whom we deal and ourselves. We therefore need to ensure that our organisation treats personal information lawfully and correctly. To this end, we fully endorse and adhere to the Principles of data protection, as set out in the Data Protection Act and General Data Protection Regulations.

In this respect, personal information:

1. shall be processed fairly and lawfully and, in particular, shall be processed only in accordance with our stated privacy policy;
2. shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes;
3. shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed;
4. shall be accurate and, where necessary, kept up to date;
5. shall not be kept for longer than is necessary for the specified purpose(s);
6. shall be processed in accordance with the rights of data subjects under the Act;
7. should be subject to appropriate technical and organisational measures to prevent the unauthorised or unlawful processing of personal data, or the accidental loss, destruction, or damage to personal data;
8. shall not be transferred to a country or territory outside the UK unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Therefore, the firm will, through appropriate management and strict application of criteria and controls:

• observe fully conditions regarding the fair collection and use of information;
• meet its legal obligations to specify the purposes for which information is used in the disclosure documentation provided to customers, obtaining consent for any marketing activities that we intend to provide;
• collect and process appropriate information only to the extent that it is needed to fulfil our operational needs or to comply with any legal requirements;
• ensure the quality of information used, regularly checking its accuracy;
• ensure that the information is held for no longer than is necessary for the purpose for which the data was originally collected, subject to our legal and regulatory obligations and legitimate business interest to protect and defend the company from litigation;
• ensure that the rights of people about whom information is held can be fully exercised under the Act (i.e. the right to be informed that processing is being undertaken, to access one’s personal information; to prevent processing in certain circumstances, and to correct, rectify, block or erase information that is regarded as wrong information);
• take appropriate technical and organisational security measures to safeguard personal information;
• ensure that personal information is not transferred abroad without suitable safeguards.
• to assist in achieving compliance with the Principles for Business of the Financial Conduct Authority:
• appoint an individual at a senior level with specific responsibility for data protection and information security assets within the firm who will be responsible for providing staff with guidance on data protection procedures.

Your information will be held securely by us and shared with:

• insurers, which could include reputable providers in other countries, to enable them to provide accurate terms and they will also obtain data about you and your insurance history from various insurance anti-fraud databases, such as the Claims and Underwriting Exchange (CUE) as well as publicly available websites and credit referencing agencies,
• other business partners/companies who perform essential services for us, such as processing our email, providing IT systems and administrative services, taking payments, sending text messages. For more information about these companies please email admin@justtravelcover.com.
• Reviews.io for the purpose of asking for customer feedback from people who buy from us (www.reviews.io/legal/user-privacy-policy).
• Zendesk who provides our online live chat software. www.zendesk.co.uk/company/privacy./#
• Smartluggage.io who provides our additional Smart Luggage Product. For information on how they process and store your data, visit smartluggage.io/privacy.
• Facebook for audience matching purposes. Your data is only used by Facebook to understand your likes and interests so they can direct marketing to others with similar likes and interests. Once they have matched the information, they delete your data.
• WDM who provide our clients with postal mail campaigns.
• IDHL who provide our clients with newsletters and updates on our service and other products available.

We will not give anyone else any personal information except on your instructions or authority, or where we are required to do so by law, or our regulatory requirements.

Information about you and your insurances will be securely stored on Socrates System internet-based server while you are a client and for a minimum of three years, and in certain circumstances up to seven years, after expiry of your policies. We will then dispose your information via the Socrates System automated process.

Under the Data Protection Act, the rights of data subjects include the following:

Data Subject Right to Rectification

If a data subject contacts the firm advising that the information held about them is inaccurate or incomplete, the firm must refrain from processing (ie. using, but not storing) the data, until it has been verified or rectified. The business encourages customers to check and correct data as disclosure is an essential element in ensuring any policy provided by the company will protect the customer.

Full notes of any allegedly incorrect information will be kept on the customer record and, although there is a 30 day period in which to rectify information once notified under the DPA, in practice this must be carried out as soon as possible and confirmed to the customer in writing (email or letter) along with the impact on their insurance of any such change.

Data Subject Right to Erasure (Right to be Forgotten)

The right to erasure is extremely limited where the data subject is a customer of the business due to the legal obligation on the firm to retain customer data for a minimum period of 3 years under FSMA and the firm’s legitimate business purposes for retention to 6 years from lapsing. Once the firm has no lawful basis for holding data it must be deleted and our policy below indicates the relevant periods for which we will hold data.

Data subjects do, however, have the right to erasure where their data is being held on the basis of consent (such as previous quotations or for marketing purposes) or their data has been processed unlawfully (such as where data has been obtained/ purchased from a third party that did not have the right to pass on that data)

Any request for erasure must be passed to the company’s data protection officer for review and appropriate action.

Data Subject Right to Restrict Processing

Individuals have the right to request that we restrict the processing (but NOT holding) of their personal data where:

• they allege inaccuracy of the data being processed (see right of rectification, above);
• data is being unlawfully processed;
• the individual has raised a formal objection to our processing of data (see Right to Object, below);
• or where the individual requests you refrain from deleting their data in order to establish or defend a legal claim (NB. In these circumstances the relevant data must be stored in a location and manner which prohibits processing of data)

Any request for restriction of processing must be noted on the file and passed to the company’s data protection officer for review and appropriate action.

Data Subject Right to Object to Processing

Again, this is a limited right which only applies in specific circumstances. Primarily in the case of Insurance Intermediaries it will be a specific right to opt-out of marketing communications.

Where a customer opts not to receive marketing communications, ++or, as a consumer, has not opted-in ++this must be noted on the client screen and their details must be removed from any marketing lists (Socrates Systems and IDHL). Confirmation should be sent to the marketing manager.

In other cases of objection, where the firm has a lawful basis for continued processing, this must be referred to the data protection officer to evaluate whether the firm’s legitimate grounds should override the data subject’s objection.

Data Subject Right to Portability of Data

The right to data portability gives individuals the right to receive personal data they have provided to us in a structured, commonly used and machine-readable format. It also gives them the right to request that we transmit this data directly to another controller, however it is important to understand that the right to data portability only applies to ++personal data.++

The right applies where the lawful basis for processing is consent or for the performance of a contract, the latter of which would apply to most of our data ++for individuals.++

Any request for data portability must be noted on the file and passed to the company’s data protection officer for review and appropriate action.

Automated Decision-Making

In connection with your application for travel insurance, we and the insurers on our panel use an automated medical screening system to screen against pre-existing medical conditions. The system will use information you provide relating to the medical history, health and lifestyle of you and any other people insured under the policy to determine whether we are able to offer you an insurance policy from any of the insurers on our panel and on what terms.

You have the right not to be subject to a decision which is based solely on automated processing, as stated in clause 9.1.6.

You do not have to take part in this screening process, but in this case, we would not be able to provide you with a travel insurance policy. In this case, please DO NOT provide your medical, health and lifestyle information to us on our website.

To the extent that you have provided (or will provide) personal information to us about any other individual, you agree that you have provided information to the individual about the content of this policy, and you have their permission or are otherwise legally authorised to share their personal information with us and the insurers as detailed in the policy. We may ask for evidence related to your authorisation, as it is part of our legal obligation to process personal data in a lawful and fair way.

Details about the way any of the insurers on our panel use your personal information can be found in their separate privacy notices which are available on their websites.

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 write to our data protection officer at Victoria House, Toward Road, Sunderland, SR1 2QF. Email: admin@justtravelcover.com, Telephone: 0333 003 0021 if you wish to exercise your rights or have a complaint about our use of your data.

Cookie Notice

What are cookies?

A cookie is a small text file, typically of letters and numbers, downloaded to your computer when you access websites. Typically, they contain the following information:

• a site name and unique user ID,
• the duration of the cookie's abilities and effects,
• and a random number.

As a rule, cookies cannot be used to reveal your identity or personally identifying information. When you visit a website that uses cookies for the first time, a cookie is downloaded onto your computer. The next time you visit that website, your computer checks to see if it has a cookie that is relevant and sends the information contained in that cookie back to the website. The website then notes that you have been there before, and in some cases, tailors what pops up on screen to take account of that fact. They also might record how long you spend on each page on a site, what links you click, even your preferences for page layouts and colour schemes.

The role of cookies is beneficial, making your interaction with frequently-visited sites smoother with no extra effort on your part. Without cookies, online shopping would be much harder and some websites will become less interactive with the cookie option turned off.

Most common cookies

Session cookies

These cookies expire when you close your web browser (Internet Explorer, Firefox, Safari, Google Chrome). These cookies are used for various reasons, for example, remembering what you have put in your shopping basket as you browse a website. They can also be used for security to access your Internet banking or email.

Persistent cookies

These cookies are still stored on your computer after you have closed your web browser which allows your preferences on websites to be remembered. These cookies are used for a variety of purposes, for example, remembering your preferences on a website (your language choice or your user name on a particular website).

First and Third-Party cookies

This refers to the website placing the cookie. First party cookies are cookies set by the website you are visiting. Third party cookies are set by another website; the website you are visiting may have advertising on the page and this other website will be able to set a cookie on your computer. Third party cookies on the main web browsers allow third party cookies by default. Changing the settings on your browsers can prevent this. We will only record or share third party cookies where we have your consent to do so. For more information about how we manage your personal data, see our privacy notice.

Exceptions

There are some exemptions to the above where it is essential for a website to store information on your computer, for example, to provide a service to you that you have requested.

Our use of cookies

Cookie Law

Data Protection laws demand that you, as a website user, are given the opportunity to understand how cookies are used on our websites and consent to cookies being stored on your computer (laptop/mobile/tablet).

How do we use cookies?

We use cookies to;

Monitor the use of our website

We put a session cookie on your computer for the duration of your visit to our site. It stores data about the browser you are using and information you have entered for our website to function correctly and to deliver you the best service. This cookie is deleted when you leave our website. We track what you do on our website to improve your experience and for functionality purposes.

Collect trend data

We also use cookies to collect trend data, which we analyse to help us improve how our site works. This trend data includes how visitors find our site and how they move around our site.

Track our marketing

We also use cookies to identify whether you have visited our site in response to one of our email newsletters or other online campaigns. This enables us to improve our email messages and send you more relevant information. To opt out of email marketing click on the unsubscribe link which appears at the bottom of all our emails or see our privacy notice for more information about how you can manage your personal data.

We also use cookies for remarketing purposes, for example, once you have been on our website and then you visit another website which has Google adverts, you may see an advert to remind you of our products and services.

To work with other selected organisations

We have partners who have referred clients and in using cookies, we track referred sales so we can compensate our partners accordingly; We also enter into agreements with commercial partners whose websites may be co-branded or framed by us and which you may visit directly through our website. These websites are not subject to our privacy policy. Please read the privacy policy of such other websites.

Use Google Analytics

We use Google Analytics on our website. How Google uses the data when you use our website may be found here. You may disable the Google Analytics function by means of a browser add- on to ensure the prevention of the sending of any analytical information to Google.

How to change your cookie settings

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

How to delete cookies from your device

To remove cookies from your computer, follow the steps in this section.

If you are using Netscape 6.0+:

Go to 'Edit' in the menu bar Click on 'Preferences' Click on 'Advanced' > Select the 'Cookies' Field > Tick either 'Warn Me Before Accepting a Cookie' or 'Disable Cookies' > Click on 'OK' > Go to your 'Start' button Click on 'Find' > Click on 'Files and Folders' > Type "cookies.txt" into the search box that appears Click 'Find Now' > When the search results appear drag all files listed into the 'Recycle Bin' > Now shut down and restart Netscape. > Depending on your earlier choice you will either be prompted by new cookies or no cookies will be set or received.

Netscape Communicator 8.0

On your task bar, click: from the Tools menu, select Options, and then open the Site Controls panel > on the Sites List tab, select the Master Setting (trust level) want to change > in the Web Features section, the default setting is Allow cookies, but you can change this.

If you are using Firefox 2.0+ / 3.0+ / 4.0+/ to disable cookies: Go to 'Tools' in the menu bar > Click on 'Options' Click on 'Privacy Tab' > Disable the box that says 'Accept Cookies From sites' > To clear existing cookies: Go to 'Tools' in the menu bar Click on 'Options' > Click on 'Privacy Tab' Click on "Clear Now" Select "Cookies" >Click on "Clear Private Data Now" >This procedure will stop sites from installing cookies on your firefox browser.

Safari 5.0 (Apple Macintosh)

From the menu choose Safari then Preferences > Click the Security icon and then Show Cookies > Select a cookie from the list and click Remove > To delete all cookies click Remove All

Managing Cookies from the Latest Firefox 8.0 Browser

You can specify your cookie options under Firefox 8.0 by selecting Tools -> Options -> Privacy. On the Privacy box, you can disallows websites from tracking you by checking on the "Tell web site I do not want to be tracked" under Tracking. But even if you are tracked, you can go to the linked "remove individual cooker" which opens up a new dialog box containing the websites and their respective cookie files saved by the browser. You can individually delete the cookies, search for specific cookie or just delete all of the with one click.

If you are using Internet Explorer (IE) 7.0+:

Go to 'Tools' in the menu bar Click on 'Options' > Click on 'Privacy' Tab on top Click on 'Advanced" button > Select "Prompt" for both "First party cookies" and "Third Party Cookies"

To delete existing cookies: Go to 'Tools' in the menu bar Click on 'Options' > Click on 'General' Tab on top > In "Browsing History" section, click on "Delete" Click on "Delete Cookies" > Your Internet Explorer 7.0 should now be cookie free!

If you are using Internet Explorer (IE) 8.0+:

Go to 'Tools' in the menu bar which should drop down then click on 'Internet Options' > Click on 'Privacy' Tab on top > Click on 'Sites' a new window should open called 'Per Site Privacy Actions' > Type in the URL of the site you wish to allow or block cookie in the 'Address of website' box.

To delete existing cookies: Go to 'Tools' in the menu bar which should drop down then click on 'Internet Options' > Click on 'Privacy' Tab on top > Click on 'Sites' a new window should open called 'Per Site Privacy Actions' > Under the "Managed websites' box should be a list of all the websites you have visited. To remove all cookies simply click on the "Remove all" button. Your Internet Explorer 8.0 should now be cookie free!

If you are using Internet Explorer (IE) 9.0+:

Go to 'Tools' in the menu bar which should drop down then click on 'Internet Options' > Click on 'Privacy' Tab on top > Move the slider up to the 'Block all Cookies' button Important Notice: Blocking all cookies may prevent you from entering a lot of sites. The next two Internet Explorer privacy levels, High and Medium High, may be more suitable.

To delete existing cookies: Go to 'Tools' in the menu bar which should drop down then click on 'Internet Options' > Click on 'General' tab which should be under 'Browsing History' and click 'Delete' > Your Internet Explorer 9.0 should now be cookie free!

If you are using Google Chrome to disable cookies:

Go to 'Tools Menu' Click on 'Options' > Click on 'Under the Hood' > 'Cookie Setting' should be selected. Once done select 'Block all Cookies' > Now all cookies should be blocked on your Google Chrome .

To clear existing cookies: Go to 'Tools Menu' Click on 'Options' > Click on 'Under the Hood' > Under 'Privacy' section select "Show Cookies' > A new window should open called 'Cookies' In here you can see all the cookies within your Google Chrome Browser. > Click on "Remove All" to remove all traces of cookies > If you wish to only remove a certain cookie, simply highlight and click "Remove"

Safari 5.0 (PC Windows)

From the menu choose Edit Then Preferences > Click the Security icon and then Show Cookies > Select a cookie from the list and click the Remove button To delete all cookies click Remove All.

If you are not using any of the above browsers, then you should select 'cookies' in the 'Help' function for information on where to find your cookie folder.