Privacy Policy

Citybond Holdings Ltd are committed to protecting your privacy when dealing with your personal information. This privacy notice provides details about the information we collect about you, how we use it and how we protect it. It also provides information about your rights and choices that you have over your personal information.

Who we are

Citybond Holdings Ltd provides contact centre and related services for Travell Insurance Facilities Plc, which is a specialist and expert travel insurance distributor: https://www.tifgroup.co.uk/about/ Our registered office is 2^nd Floor, 1 Tower View, Kings Hill, West Malling, ME19 4HA.

Scope of our privacy policy

This privacy policy applies to anyone who interacts with us about our products and services for the purchase of travel insurance it also applies to you if you are enquiring about our products and services by obtaining a quote. The privacy policy describes how we handle your data, regardless of the way you contact us (for example, by email, through our website, by phone or possibly even on our social media platforms and or by signing up to our newsletter We have therefore developed this privacy policy to inform you of the data we collect, what we do with your information and what we do to keep it secure as well as the rights and choices you have over your personal information.

Should you require further information, then please contact us using the contact details below and we will be happy to provide you with further information.

This privacy policy is intended to be easy to read and has been set out in a layered format with a Glossary in order that the meanings of some of the terms used in this privacy notice can be easily understood.

Important Information and the purpose of this privacy policy
Changes to the Privacy Notice and your duty to inform us of changes
The data we collect about you and how the law protects you
How is your personal data collected?
How we use your personal data
Disclosures of your personal data
Transfer of Data outside of the EEA
Automated decision making and profiling
Data security
Data retention
Your legal rights
Glossary

Important information and the purpose of this privacy notice

It is important that you read this privacy notice together with any other privacy notice or fair processing notice, 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 notice supplements the other notices and it is not intended to override them.

For the purpose of Data Protection Laws, the following shall have the meanings set out below:

‘Data subject’ A data subject is the person about whom personal data is being collected, processed and stored.

‘Personal data’ is information about an identified or identifiable natural person that could allow a living person to be identified.

With your information, we will provide you with a quotation and/or administer your insurance policy. For this reason, we are classed as the ‘data controller.’ Your data may be shared with other parties, including the insurers, for the purpose or arranging insurance.

Citybond Holdings Ltd is registered with the Information Commissioners Office, registration number:Z705301X.

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). 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 Notice and your duty to inform us of changes

We may change this page from time to time, to reflect how we are processing your data. If we make significant changes, we will make that clear on our website.

It is important that the personal data we hold about you is accurate and updated. Please keep us informed if your personal data changes during your relationship with us.

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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details. Financial data will be encrypted accordingly.
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.
Profile Data includes your username and password, 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.
Health and Medical Information includes medical history obtained from you, GP records (with your express consent), medical reports from hospitals abroad and other medical information required to fulfil our obligation as your travel insurance provider.

If you fail to provide 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 travel insurance products. 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.

How is your personal data collected

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by purchasing travel insurance products through our contact centre or through our website online, including correspondence with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
Create an account on our brand websites;
Subscribe to our service or publications;
Request marketing to be sent to you;
Enter a competition, promotion or survey;
Give us some feedback.

How we use your personal data

Before you provide any data to us, we will endeavour to make it clear why we need it. We will only use your personal data when the law allows us to.

Where it is necessary for us to perform the contract of insurance.
Where it is necessary for our legitimate interest (or those of a third party) and in circumstances, we may send data or reports to the insurers and we may also send data or reports to our regulators.
Where we need to perform our obligations within your contract accounts will provide refunds, reports and answers to payment queries.
Where we arrange and administer your policy if you buy through us.

To find out more out more visit, https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/ about the types of lawful basis that we will rely on to process your personal data.

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 via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purpose 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 basis 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 ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose	Type of data	Lawful basis for processing including basis of legitimate interest
To send reports to the Insurers of incidents that the Insurers need to be aware of.	Identity Health and Medical Information	a) Necessary for our legitimate interests (to pursue assistance from insurers)
To provide a refund.	Identity Contact Financial	a) Consent b) Our legal and Regulatory obligations
To manage our relationship with you which will include contacting you by: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	(a) 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) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	(a) 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 collect and recover money that is owed to us	Identity Health and Medical Information	Necessary for our legitimate interests in recovering money that is owed to us.
To use the personal data of new customers for marketing other products or services (where you’ve opted in)	Identity detailsContact details	Consent from you to be able to contact you about our products and discounts that may be of interest to you. Necessary for our business legitimate interests
To use the personal data of existing customers for marketing similar products and services (where you haven’t opted out)	Identity detailsContact details	Consent from you to be able to contact you about our products and discounts that may be of interest to you. Necessary for our business legitimate interests
To collect and process your personal data through cookies to optimise your customer experience, to develop new ways to meet our customers’ need, to grow our business and to identify and prevent fraud	Technical Usage	Necessary for our legitimate interests to optimise your customer experience and for us to develop new ways to meet customer’s needs. To help grow our business and to identify and prevent fraud.
To report and provide data (including personal data) to government organisations e.g. Police, regulators, Courts	Identity detailsContact detailsUsage dataHealth and Medical information	Legal ObligationNecessary for our legitimate interests to co-operate with, assist and provide information to regulators and other authorities
To help identify, prevent, investigate and report potential fraud	Identity detailsContact detailsHealth/Medical informationFinancial information	Compliance with a legal obligation to report fraud and our legitimate interests to investigate suspected fraud and share data with fraud prevention agencies.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly in marketing and advertising. We have established methods to provide you with an option to make a decision whether you would like to receive marketing materials. If you would like us to stop sending certain or any marketing materials you may opt-out by contacting us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or 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 purchased insurance products from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving these communications from us.

Third-party marketing

We will get your explicit opt-in consent before we share your personal data with any company other than Citybond Holdings Ltd for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
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 purchase as we may still need to contact you as part of your contract of insurance.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

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.

Disclosures of your personal information

We may have to share your personal data with the parties set out below for the purposes set out in the table above ‘legal basis for processing data’

External Third Parties as set out in the Glossary.
Third parties to whom we decide to go into business with, for example, sell travel insurance on their behalf. 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 notice.
If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or
From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it.

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.

Transfer of data outside of the EEA

We may transfer personal data to, and process personal data in a country outside of the European Economic Area (EEA). If we do transfer your data outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. In most cases, this will be by using approved EU approved contractual clauses. We may also process your data in countries which have reached Adequacy Decisions with the European Commission, or are part of the Privacy Shield in the US.

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they too will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. They also require the recipient to subscribe to ‘international frameworks’ intended to allow secure data sharing.

Automated Decision Making & Profiling

Automated decision-making is the making of a decision about you based solely on automated means without any human involvement. This occurs when we conduct a medical screening at the beginning of your customer journey either online or through our call centre. The system is pre-programmed algorithms that assist in calculating your premiums.

You have the right to object to profiling and automated decision-making as set out below. In these circumstances, you have the right to request an adviser of Citybond Holdings Ltd to review the automated decision, as part of this process you also have the option to let Citybond Holdings Ltd know the reason for your objection and ask us for a reconsideration of the decision. You can contact Citybond Holdings Ltd to exercise these rights.

By law, we must tell you when we rely on an automated decision-making process, (making a decision using technology, without any person being involved). This occurs when we conduct a medical screening at the beginning of your customer journey either online or through our call centre. The system is pre-programmed algorithms that assist in calculating your premiums. We are also required to tell you when we use profiling (automated processing of your information to help us evaluate certain things about you, for example, your personal preferences and your interests) for example:

Underwriters: our underwriters will assess risk, calculating premiums and what kind of cover we can offer. The type of data we will process are Identity Data and information about your trip for us to understand the likelihood of a certain event that may occur. With the results, we will determine the premiums and extent of cover.
Medical screening: we use a risk rating tool which determines the answers given to the relevant questions that we deem relevant to purchase insurance. This permits us to understand the risk of the medical condition declared against factors such as the destination chosen, duration of the holiday, and type of trip you have chosen to go on.

When Citybond Holdings Ltd makes a decision about you using automated processing which has a significant impact on you, we will let you know as part of your customer journey. You then have 21 days to ask us to reconsider our decision or to make a new decision using human intervention rather than automated processing. If we receive a request from you, within 21 days of receiving your request, we will:

consider the request, including any information you have provided that is relevant to it;
meet your request; and
let you know in writing what we have done to meet your request and the outcome.

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 or disclosed. 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.

Our IT estates are protected by enterprise-level hardware-based firewall systems, with scans being performed regularly to ensure that any vulnerabilities are quickly found and patched. Annual penetration tests are performed by external parties. All services have auto fail-over points and redundant hardware, with complete backups performed as a minimum daily. Access to systems is severely restricted to specific individuals, whose access is monitored and audited. Access levels are granted based on user role and changes are subject to strict pre-approval processes. All client data encrypted at rest and is stored within UK based data centres. Our applications utilise Transport Layer Security (TLS) & Secure Socket Layer (SSL) encryption (also known as HTTPS) for all transmitted data. We also protect applications with encrypted passwords.

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

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

Your legal rights

You are entitled to the following:

A copy of the personal data we hold for you, by making a subject access request.
Have your data corrected if it’s wrong or incomplete.
Have your data deleted or removed if it’s no longer needed.
Restrict the processing of your personal data.
Withdraw any permission you’ve given in respect of your personal data (including marketing). You can unsubscribe by clicking on the unsubscribe button on our email communications or by contacting us directly.
Data portability – to keep and re-use your data in an electronic form for your own purposes or to ask we pass the information to another organisation.
Get human intervention on the part of the controller, where you are subject to a decision based solely on automated processing, including profiling, which has a significant effect on you, to express your point of view and/or to contest the decision.
Object where we’re processing your information on the grounds of it being our legitimate interest to do so.

We will uphold your rights to the best of our abilities; however, data protection laws allow us to continue to process your personal data if we have a legitimate reason, legal or contractual obligation to do so. For example, if data is needed for fraud prevention or legal requirements.

If you wish to exercise these rights set out above, please contact us. Should you wish to make a Subject Access you can do so by contacting us on the details provided above. You have the right to make the request verbally or in writing.

No fees 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. If another individual is making the request on your behalf, we will always ask for your explicit consent prior to sending your subject access request out to you via a secure method.

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 this case, we will notify you and keep you updated.

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.

Third Parties

Service providers acting as processors such as IT suppliers, auditors, marketing agencies, document management, transcribers, recovery agents;
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances or who we co-operate with or assist;
Our insurance partners such as brokers, insurers or other companies that act as distributors;
Fraud detection agencies and other third parties who operate and maintain fraud detection registers;
The police and other third parties or law enforcement agencies, where reasonably necessary for the prevention or detection of crime;
Overseas assistance companies
Market researchers acting as the processor to provide the best customer experience;
Third party companies who carry out customer feedback surveys on our behalf;
Marketing Companies that provide an email platform only and not direct marketing for sending out our customer feedback surveys; the third party will also manage the individuals who unsubscribe from feedback emails.
Third party marketing companies who send out marketing material on our behalf where we have obtained valid consent. The third party in this instance also manages the individuals who wish to unsubscribe from receiving such material from us.
Charities acting as processors to provide customers with gift aid;
Affiliates acting as processors that use advertising methods which include organic search engine optimisation (SEO), paid search engine marketing (PPC – Pay Per Click) and e-mail marketing;
Social Networks;
Customer Experience tools that show us your journey of how you navigate the website for a better understanding to improve your customer experience; and
Competition surveys.