Privacy Policy

INTRODUCTION

Halo Insurance Services Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when visit our website (regardless of where you visit it from) or otherwise access any of our products and services and tell you about your privacy rights and how the law protects you.

The General Data Protection Regulation (EU) 2016/679 (“GDPR”) is a regulation in EU law on data protection and privacy for all individuals within the European Union (EU) and the European Economic Area (EEA). It also addresses the transfer of personal data outside the EU and EEA areas. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU.

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Halo Insurance Services Ltd collects and processes your personal data

It is important that you read this privacy policy together with any other policies 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 policy supplements the other policies and is not intended to override them.

CONTROLLER /JOINT CONTROLLERS

Halo Insurance Services, and Covermore UK is the controller and responsible for your personal data (collectively referred to as “COMPANY”, “we”, “us” or “our” in this privacy policy). Except where:

our partners and Insurers including Zurich Insurance plc, MAPFRE ASISTENCIA and other companies whose products or services are featured on our Sites, with a view to them: (i) providing you with an Insurance product, or other service which you have requested. When these companies use your personal information in this way, they will be acting as data controllers (or Joint Data Controllers, alongside Halo) of your information and therefore we advise you to read your chosen provider's Privacy Policy.

We have appointed an external data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the external DPO using the details set out below.

exercise your legal rights, please contact the external DPO using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Halo Insurance Services Limited (company number 69229208)

Postal address: registered address is

Suite 1, 56

Gloucester Road,

London, SW7 4UB.

Name of external DPO: Robert Healey

Relentless Privacy and Compliance Services Ltd (company Number 12175923)

Email address: robert.healey@relentlessdataprivacy.com

Postal address:

Colmore House, Queensway,

Birmingham,

B4 6AT United Kingdom.

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). There full postal address is

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

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 POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 07/03/2020 and historic versions 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 policy 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, last name, username or similar identifier, title and date of birth.
Contact Data includes billing address, home address, email address and telephone numbers.
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, unique mobile device identification numbers (such as your Media Access Control (MAC) address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI), type of device, 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 login details, 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.

If you decide to make a payment for any of our products and services, your Financial Data, which includes your bank account and payment card details, will be collected by our external payment service provider. Our payment processing is PCI compliant.

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 policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3: HOW IS YOUR PERSONAL DATA COLLECTED?

We may obtain personal information from you through the websites, mobile applications or other similar devices, channels or applications operated by or on behalf of any of the following brands (referred to collectively in this Privacy Policy as the "Sites"): • iCarhireinsurance.com; • iCarhireinsurance.ie; • InsuretheGap.com, • leihwagenversicherung.de, • huurautoverzekering.com, • asseguramicochedealquiler.es, • assicurazioneautonoleggio.it, • assurancelocationvoiture.fr • haloinsurance.com • and the iCarhire App.

Halo Insurance Services Limited is owned by its parent Company Cover-More PTY Ltd (Registered in Australia ACN 609 090 397), however we do not share control of your personal data within this wider group. In some circumstances, group companies may be used to perform some data processing functions on behalf of Halo, but this will not provide any group companies with authorisation to use your data outside of these specific functions.

We use different methods to collect data from and about you including, but not limited to:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our products or services.
subscribe to our service or news.
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, pixels, 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.
When requesting a quote, the information you share with us could be subject to automated processing to provide you with an accurate price for your cover. We only use this processing for:
- where the decision is: necessary for the entry into or performance of a contract

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

- Technical Data from the following parties:
  - (a) analytics providers such as Google based inside AND outside the EU;
  - (b) advertising networks such as Facebook based inside AND outside the EU; and
  - (c) search information providers such as Google based inside AND outside the EU.
- Contact, and Transaction Data from providers of technical, payment and delivery services based inside AND outside 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:

For the performance of the 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 need to comply with a legal or regulatory obligation, for example, if required to do so by any court, the Financial Conduct Authority, the Competition and Markets Authority or any other applicable regulatory, compliance, Governmental or law enforcement agency.

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. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES 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.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data

Purpose / Activity	Type of Data	Lawful basis for processing including basis of legitimate interest
To provide a quote for the insurance product you are enquiring about”	Identity	Article 6 1b: Steps are required prior to a contract with the data subject. processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data,
To process and deliver your order including: (a) Manage payments, fees and charges (b) Obtain consent for marketing activities performed by third parties	Identity Contact Transactional Marketing and communications	Article 6 1b: performance of a contract with you Article 6 1 (a)the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
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	Identity Contact Transactional Marketing and communications	Article 6 1b: performance of a contract with you Article 6 1 (a)the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Marketing and communications	Article 6 1b: performance of a contract with you Article 6 1 (f) 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)	Identity Contact Transactional Profile Usage	Article 6 1 (b)Performance of contract Article 6 1 (f) 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) Article 6 1 (c) Necessary to comply with a legal obligation Article 6 1 (f) Necessary for our legitimate interests to detect or prevent unlawful acts
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage Marketing and Communications Profile	Article 6 1 (f) 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	Identity Contact Transactional Profile Usage	Article 6 1 (f) Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or registered an interest in our products and services from us or if you provided us with your details when you entered a competition or registered for a promotion.

THIRD-PARTY MARKETING

We will get your explicit opt-in consent before we share your personal data with any company outside Halo Insurance Services Ltd for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting our customer services team or by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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 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. DISCLOSURE OF YOUR PERSONAL DATA

In connection with the purposes described above (see paragraph four), we sometimes need to share your Personal Information with third parties (this can involve third parties disclosing Personal Information to us and us disclosing Personal Information to them).

These third parties may include: 3rd Party processing partner categories below

Type of Third Party	Examples
Our group companies	Such as Cover-More Insurance Service Limited, Cover-More Group Limited and Zurich plc.
Other Insurance and Insurance distribution parties	Such as Zurich plc, MAPFRE Asistencia or other insurers we may work with from time-to-time
Our Service Providers	Including professional services companies such as e-Financial Management, Mazars Chartered Accountants, and marketing support and hosting companies, such as Salesforce, Amazon Webservices, Cloud IQ, Hotjar, Google and Microsoft
Government authorities and third parties	Such as the Courts of England and Wales, The Financial Conduct Authority, and HMRC

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 policy.

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.

INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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, disclosed or being unavailable. 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.

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.

DATA 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six tax years plus current tax year after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notification.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. We set out below a brief description of such 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 your personal data: 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 your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy; or
- 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

If you wish to exercise any of the rights set out above, please Contact us.

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 which case we will inform you of an extension period of up to 2 months. In this case, we will keep you informed on progress.

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.

Explicit consent for external marketing means your personal data will not be disclosed to any third party unless you have given your explicit consent to such disclosure.

POLICY UPDATES

We may update our Privacy Policy from time to time to reflect changes in technology, legislation, our operations, or as we otherwise determine is necessary or appropriate. Any such changes will become effective when we make the revised policy available on our website. We encourage you to review the date above frequently to ensure you are aware of when our policy was last revised, and to help you better understand the nature of your interactions with us