1: Introduction

This Privacy Policy is for anyone who uses our services (herein referred to as ‘you’ or ‘customers’), including policyholders, prospective policyholders who for example have requested a quotation or submitted an enquiry, website users and beneficiaries of any of our policies. It should be also brought to the attention of any party who is directly involved in your policy, where they have given you consent to act on their behalf.

This Privacy Policy is issued by International Private Healthcare Limited group of companies, including IPH Insurance Services (UK) Ltd, which you may know as ‘IPH’ or ‘IPH Insurance’. Herein these companies will be referred to as ‘we’, ‘our’, or ‘us’.

We are a data controller and processor of your personal information. We want to make sure all of our customers know exactly how their personal data is being used by us, how we protect that data, and what you can do to control how we use your data.

Your broker will have their own policy for your personal data, please ask your broker if you would like more information about how they use your personal information.

2: What information do we collect?

We collect information that is personal to you, such as your name, address, contact details, date of birth, criminal convictions, medical history, claims history, IP address (which is a unique number which can be used to identify your computer), payment details, and any other information relating to the things you want to insure. Where necessary, we also collect special categories of sensitive personal information, and criminal offence data.

3: How do we collect your information?

We collect information from various sources, which may include but is not limited

  • Enquiry, proposal, claim, survey and feedback forms
  • Telephone
  • Post
  • Email
  • Your broker
  • Other policyholders, insureds, or policy beneficiaries
  • From individuals who have policies with us under which you are insured
  •  Publicly available data, such as that on social media and networking sites or the electoral register
  • Third party databases available to us for fraud prevention provided by law enforcement or government agencies
  • The HM Treasury, OFAC and other financial sanctions lists such as those from the EU, UN and Australia (DFAT)
  • Witnesses to an incident related to a claim
  • Credit reference agencies
  • Loss adjusters
  • Suppliers and third party administrators appointed in the process of handling a claim
  • Promotional competitions, prize draws, events

4: What do we use your information for?

  • We primarily use your personal information in order to uphold and fulfil our contract of insurance with you. We may use your personal information to:
  • Decide or underwrite the risk when providing you with a quotation and price
  • Apply for an insurance policy with your insurer
  • Help us answer any questions you may have
  • Administer your policy and any premium payments
  • Update your personal details relating to your insurance
  • Change the cover you have on your policy
  • Contact you about your insurance
  • Discuss your policy with your broker to help them manage your insurance with us
  • Provide assistance if you make a claim

We may also use your information as required according to the law, including:

  • Register a complaint related to you
  • Fulfil and comply with our legal and regulatory obligations
  • Prevent fraud and financial crime (which may include processes that identify you)

We may process special category of sensitive information and criminal offence data if we have a lawful basis and fulfil the appropriate condition for doing so.

We may use your information to protect anyone’s vital interests. This means we may have to use your data to protect someone’s life.

We may also use your information for legitimate interests, which is primarily to improve our services and marketing communications. This might include for example your marketing preferences and consent, data related to promotional competitions/prize draws/events, and your responses to voluntary customer satisfaction surveys.

5: Sharing your information

We may share your personal information with third parties for the reasons outlined above. Unless required to by law, we would never share your personal data without the appropriate care and necessary safeguards being in place.

In particular we may share information with:

  • An individual you have authorised us to speak with us on your behalf
  • Financial crime & fraud prevention agencies
  • Regulatory bodies
  • Claims and Underwriting Exchange and other databases
  • Credit search and identity check
  • Incidents or claims
  • Public information
  • Industry databases
  •  Brokers and other insurers
  • Reinsurers and reinsurance broker
  • Motor Insurance Database
  • Flood Re
  • Medical and other health services
  • Claimants
  • Other insured parties
  • Law enforcement and government agencies

In order to fulfil some of the purposes outlined in Section 4 we may have to send, store or process your personal information overseas. The protections given to your personal information in other parts of the world may not be the same as in the UK. Where possible, we will put in place contractual transfer agreements to ensure that your personal information is safeguarded with the same high level of protection that we commit to.

In some cases we might need to share information to carry out the services we have promised to carry out, for example if you require urgent medical assistance abroad. In such an urgent situation we may not always have the time to put in place the type of agreement we would normally want to.

6: Others acting on your behalf

If you would like somebody else to talk to and deal with us about your policy, please let us know. We may only do so if:

  • You have given us written authorisation nominating the individual you wish to act on your behalf
  • They are your legal representative, or
  • They are your attorney through a lasting power of attorney or enduring power of attorney.

7: How long we keep your information for

We will keep your information for as long as is necessary for the purposes and in order to comply with our legal and regulatory obligations. The precise period will depend on the type of personal information and on the purpose for which we hold your information. In some cases, such as if there is a dispute or a legal action we may be required to keep personal information for longer.

Here are some general guidelines:

8: Marketing and digital data

How we use and protect your information for marketing

We may use your information to carry out research and analyse data to help us understand more about our customers, analyse our competition in the market, and to improve our marketing activities.

IPH strongly believes in keeping the personal information you have entrusted to us private and protected, and we will never provide your personal information to third parties for marketing purposes.

You may control which methods of direct marketing you receive from us:

  • Email messages: if you wish for us to stop sending you marketing emails please click ‘unsubscribe’ at the bottom of the email, follow the on-screen instructions and you will automatically be removed from our email list. Alternatively you may contact us and request us to remove your email address off the list for you.
  • Postal mail: if you wish for us to stop sending you marketing packs in the post, please contact us and request us to remove your postal address off the list for you.

Please also note that if you choose to opt out of receiving marketing communications from us, we may still send you other important service and administration communications relating to our services to you. You cannot opt-out from this as it is important you receive these correspondences in order for us to carry out our services for you in compliance with our legal and regulatory obligations.

What digital data we use

We may collect other information about your use of our digital platforms e.g. our website, and the devices you use to interact with us, for example:

  • internet browser and electronic device information
  • information collected through cookies, pixel tags and other similar technologies
  • information you have submitted via our digital platforms
  • demographic information
  • geographical information, and
  • aggregated data.

Some of this information will personally identify you but others will be anonymised.

Cookies

Here are the cookies currently used on our website:
Cookie name Party What it’s used for
Google analytics cookies First party To analyse your use of our website, including the time you spend on the site, the number of pages you visit, etc

9: Your rights

You have a number of rights to your personal data as set out by data protection law. If you wish to exercise any of these rights, please get in contact with us using the details provided in Section 11.

Access

You may request a copy of all the personal data we hold about you and any supplementary related data. There will not usually be a charge for these requests.

Rectification

You may ask us to amend information that we have about you that may be incomplete or incorrect. This request may be done verbally or in writing.

Erasure

You may ask us to delete personal information we have about you, for example where the personal information we collected is no longer necessary for the original purpose.

Restrict processing

You may restrict our use of your personal data so that we may store it, but not use it. This request may be done verbally or in writing.

Data portability

You may move, copy or transfer your personal information from one IT environment to another without affecting its usability. We may offer to transmit your requested personal data either to you directly, or directly transmit your data to a recipient which you have authorised.

Object

You may object to our processing of your personal data, including for our direct marketing purposes.

Withdraw consent

If any of our processing activities rely on your consenting to us collecting and using your personal information, you may withdraw your consent for our use of such information for these activities, at any time.

Complain

If you have any concerns about the way we use your personal information, please get in touch with us. You also have the right to complain to the Information Commissioner’s Office, for more information please go to https://www.ico.org.uk.

10: Changes to this Privacy Policy

Please note that we may need to make changes to this Privacy Policy from time to time. Any changes will be updated on our website. If appropriate, we may also notify you of this in writing.

11: How to contact us

If you have any queries or requests resulting from this Privacy Policy please use the details below.
Email: [email protected]

Postal Address IPH House, Stirling Way
Borehamwood
Hertfordshire
WD6 2BT
United Kingdom
Telephone +44 (0)20 8905 2888
Fax +44 (0)20 8207 2878