Privacy Policy

This privacy notice will help you understand how we collect, use and protect your personal information. You should also show this notice to any named persons on your policy and anyone else whose details you provide to us. In order to make sure that the data we hold is accurate please tell us if there are any changes or errors in the data that we hold. You have the right to rectify the data we hold under the Data Protection Act 2018.

During the life of your policy, we may need to contact you with important information which we will do using the contact details you have given us.

You can manage your communications preferences when taking out the policy or unsubscribe at any time by contacting our racservice@hoodtravel.co.uk.

This policy may include links to websites other than ours and these will contain their own privacy and cookie notices.

There are multiple organisations involved in providing you with a travel insurance service. This privacy policy explains how the following organisations process your data:

• Hood Travel Limited (“Hood”) which sells and administers the policies and provides customer services facilities;

In this privacy notice, ‘we’, ’us’ and ‘our’ refers to Hood unless otherwise stated.
There are other organisations which are also involved, and these have their own separate privacy policies which are included below this one. These are:

• RAC Financial Services (“RAC”) who promotes the product and uses your personal data to communicate with you during the lifetime of the policy for their own legitimate purposes. You can find out more by reading their privacy policy here https://www.rac.co.uk/privacy-policy
• ERGO Travel Insurance Services Limited (ETI) which underwrites the policies and is responsible for claims handling.
• Taurus Insurance Services Limited which provides the gadget cover and is responsible for gadget claims handling; Their privacy policy can be found here https://www.taurusgadgetinsurance.com/privacy-policy
• DAS Legal Expenses Insurance Company Limited which provides the legal cover and handles claims for such cover. Their privacy policy can be found in the policy wording.

If you received a quote for your policy before 4th September 2023, it would include cover for Financial Failure provided by International Passenger Protection.

• International Passenger Protection Limited which provides the airline and supplier failure cover and handles claims for such cover; and their privacy policy can be found here https://www.ipplondon.co.uk/privacy.asp

The type of personal information we collect.
The types of information processed are shown in the table below. The identity of the data controller for each type of information is also shown. Where both parties are data controllers they act independently for that purpose.

Data	Data Controller
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.	ERGO Hood
Contact Data includes billing address, postal address, email address and telephone numbers.	ERGO Hood
Financial Data includes bank account and payment card details to purchase a policy. Financial data will be encrypted accordingly.	Hood
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.	Hood
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.	Hood
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.	Hood
Usage Data includes information about how you use our website, products and services.	Hood
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.	Hood
Health and Medical Data includes medical history obtained from you.	ERGO

How we get the personal information and why we have it
The personal information we process is provided directly by you to us when you are applying for a quote for a travel insurance policy (by telephone or submitted through the website) or when you contact our customer services department (by telephone, email, post or real-time web live chat). This information may be shared with ERGO to fulfil their own purposes.
The contact details we process will be shared with RAC who will keep in touch regularly, sending you communications on their products and services.
Each of us use the information that you have given for different purposes which are listed in the table below along with the identity of the company to which the purpose relates.
We will only share your information if it is allowed by law, for prevention of fraud or with third parties who perform services to administer your policy. These include our respective group companies, price comparison website providers, third party administrators, other insurance intermediaries, insurance reference bureaus, medical service providers, fraud detection agencies, external law firms, external accountants and auditors, regulatory authorities, and as may be required by law.
Under data protection legislation, the lawful bases each party relies on for processing this information are in the table below.

Lawful Basis	Hood	Ergo	Definition
Contractual obligation	x	x	To deliver a contractual service
Legal obligation	x	x	To deliver a statutory obligation
Legitimate interest	x	x	To use the data in a way that would be reasonably expected, for example to generate an insurance premium

Purpose	Company	Lawful Basis
Pricing risk rates	ERGO	Legitimate interest
Operations (assistance/claims validation, fraud investigations)	ERGO	Contractual obligation
Assistance and Claims Complaints	ERGO	Contractual obligation
Pricing retail rates	Hood Travel
Amendments to and renewal of a travel insurance policy	Hood Travel	Contractual obligation
Providing you with policy documentation relating to a contract of insurance	Hood Travel	Contractual obligation
Providing a customer services facility via telephone, email and real-time web live chat	Hood Travel	Contractual obligation
Complaint’s handling (non-claims complaints)	Hood Travel	Contractual obligation
Processing premium payments and refunds	Hood Travel	Contractual obligation
Screening against the HM Treasury financial sanctions list	Hood Travel	Legal
Prevention and detection of financial crime	Hood Travel	Legal
Marketing	Hood Travel	Legitimate interest
Providing you with information we believe may be of interest to you related to your travel insurance policy	Hood Travel	Legitimate interest
Understanding how people interact with the travel insurance website	Hood Travel	Legitimate interest
Recording phone calls for record keeping, training and monitoring	Hood Travel	Contractual obligation

Automated Decision Making
ERGO and Hood use automated decision making, including profiling, to assess insurance risks, detect fraud, and administer your policy. This helps decide as to whether insurance can be offered and determine prices.
An example is that when you buy a travel insurance product, a potential policyholder may be rejected for cover based on their age. ERGO do not offer insurance for customers above a certain age. If accepted, the automated calculation of a person’s age may be used to calculate the premium payable.
If you have any concerns regarding the decision reached, please let Hood know at the contact details set out below and we will arrange for a person to check the accuracy of the result.
How we store your personal information
Your information is securely stored within the United Kingdom.
We keep your personal data for:

• thirteen months after the date you request a quote; or
• in the case of a purchased policy, seven years after it has expired.

We will then dispose of your information by deleting it from our systems.

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 Hood Travel using the details provided under ‘Our contact details’ if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us using our contact details in the table below.

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

Our contact details

Company	Hood Travel Ltd
Address:	2nd Floor, Dencora Court Tylers Avenue Southend-on-Sea Essex SS1 2BB
E-mail:	dpo@hoodgroup.co.uk