Travel Insurance Privacy Policy

This Privacy Policy explains how we use Personal Information which we collect about individuals in relation to travel insurance policies.

We take the security of your Personal Information very seriously. We use a combination of technical, organisational and physical security measures to protect your Personal Information in line with our obligations under data protection law. Our employees receive training to help us comply with data protection law and safeguard your privacy.

This Privacy Policy is issued on behalf of the Aviva group companies within the United Kingdom. When we mention "Aviva", "we", "us" or "our", what we mean is the relevant company in the Aviva group that processes your Personal Information.

Each Aviva group company that processes your Personal Information is responsible for looking after it in accordance with this Privacy Policy. Where you are an individual policyholder, the Aviva group company that underwrites your insurance policy will be the main company responsible for your Personal Information, known as the controller. Please check the documentation that we provide to you for details of the specific Aviva company acting as controller of your Personal Information. If you are unsure, please contact us. We may share your Personal Information in accordance with this Privacy Policy with other companies in the Aviva group (including Wealthify Limited).

We have separate privacy notices for our different types of products, so if you have a number of Aviva products you may need to review more than one privacy notice. We may also supplement this Privacy Policy with additional privacy notices tailored to our specific relationships with you where this is useful to provide you with a full picture of how we collect and use your Personal Information. This Privacy Policy supplements – but doesn’t override – them.

Most of the Personal Information we collect relates to the individual who is taking out a policy (or individuals where it’s taken out jointly or otherwise for the benefit of others). We may also ask for Personal Information about other individuals if we need it. For example, if you ask us to provide insurance for someone other than you, e.g. other household or family members. If you provide us with Personal Information about someone else, we’ll assume that you have their permission, where required. We’ll process their Personal Information according to this Privacy Policy so please encourage them to read it if they want to find out more.

In connection with the purposes set out above, we will sometimes share Personal Information with Aviva group companies and third parties, including:

• Insurance brokers, financial advisers and business partners, who help us arrange, manage and underwrite our products and who provide insurance services;
• Other insurers;
• Our insurers or reinsurers (either directly or through insurance brokers), who provide reinsurance services to us and each other in respect of risks underwritten by Aviva, or insurers who cover Aviva under our group insurance policies. We can supply on request further details of the insurers and reinsurers we provide your Personal Information to and how this may be used. If you require further details, contact us;
  
• Third parties who provide you with services relating to your product, e.g. travel assistance providers and healthcare providers;
• Third parties who provide us, or a third party insurer relevant to your product or claim, with services, e.g. loss adjusters, claims handlers (e.g. CEGA Group Services Limited) assistance providers, third-party case managers handling your care or treatment pathway, experts and, in limited circumstances, private investigators;
• Medical professionals, if we need to access health records or assessments for the purposes of arranging and underwriting certain products or facilitating and handling claims;
• Legal advisers, accountants, auditors, financial institutions and professional service firms who act on our or your behalf, or who represent a third-party claimant;
• Data analysts and providers of data services who support us with developing our products and prices and measuring the effectiveness of marketing;
• Third parties that help us maintain the accuracy of our data e.g. by identifying individuals who are deceased, updating contact details for individuals who have moved and payment card providers who provide us with updated payment card details; financial crime detection agencies, sanctions checking providers and third parties who maintain fraud detection databases or provide assistance with investigation in cases of suspected fraud;
• Regulators who regulate how we operate, including the FCA, PRA, FOS, HMRC, ICO and the Advertising Standards Agency;
• Government agencies and regulatory bodies including the police, courts, Driver and Vehicle Licensing Agency (DVLA) and the DWP;
• Debt advisors, including where breathing space is requested on outstanding debts;
• Insurance industry bodies, including the Association of British Insurers;
• Credit reference agencies;
• Service providers, including those who help operate our IT and back office systems, underwriting and claims processes and our information security controls;
• Third party payment service providers, including Adyen NV, who process card and other payments for us. For full details of how Adyen use your Personal Information when completing a transaction please refer to their privacy policy;
• Medical professionals, if we need to access health records or assessments for the purposes of arranging and underwriting certain products or facilitating and handling claims;
• Research agencies and providers of market research services, including customer feedback surveys;
• Providers of marketing and advertising services, including delivering and administering marketing, ensuring you receive marketing content that’s relevant to you and in accordance with your preferences and analysing marketing campaigns. These may include media agencies, fulfilment partners, social media and other online platforms and advertising technology companies. You can find further information about this in the section on Marketing; and
  
• Third parties in connection with any sale, transfer or disposal of our business.

Some of the organisations we share information with may be located outside of the UK. For further information, please see the section on International Data Transfers.

We use your Personal Information to detect and prevent fraud and other financial crime including to meet our statutory and regulatory responsibilities in relation to fraud and financial crime.

If you’re making an application or a claim, we may use profiling and other forms of automated processing to assess if your application or claim may be fraudulent. This assessment may involve the use of Sensitive Personal Information. For further details, see Automated Decision Making.

We may also use your Personal Information including details of our interactions with you to help us detect fraud committed by brokers or financial advisers or to identify where you or a third party may be at risk of fraud or other financial crime. 

To prevent, detect and investigate fraud and financial crime, we:

• check public registers (e.g. the electoral roll or registers of county court judgments, bankruptcy orders or repossessions);
• conduct online searches from websites, social media and other information sharing platforms;
• use databases managed by credit reference agencies, insurance industry bodies, fraud detection agencies and other reputable organisations. This includes the Insurance Fraud Bureau whose Privacy Policy can be viewed here; and
• share Personal Information and undertake searches with other third parties, including other insurers, fraud prevention agencies, law enforcement agencies, public bodies and our regulators (which include the FCA, PRA and ICO).

This will help us verify your identity, make decisions about providing you with our products and related services e.g. paying claims and trace debtors or beneficiaries. 

If you give us false or inaccurate information and we suspect fraud, we’ll record this to prevent further fraud and money laundering and this may be shared between insurers.

We can supply on request further details of the agencies and databases we access or contribute to and how this information may be used. If you require further details, please contact us.

To ensure we have the necessary facts to assess your insurance risk, verify your identity, help prevent fraud and provide you with our best premium and payment options, we may need to obtain information relating to you at quotation, renewal and in certain circumstances where policy amendments are requested. We or our agents may undertake checks against publicly available information (e.g. electoral roll, county court judgments, bankruptcy orders or repossession(s)). Similar checks may be made when assessing claims.

Information about the credit reference agency we use and the ways in which they use and share Personal Information, are explained in more detail on the TransUnion website.

We may use automated processes to make decisions. These automated processes use data provided by you, other records we hold about you in our systems and data sourced from third parties to make predictions, including the likelihood that a claim will be made and its value, the likelihood a product will be purchased and the likelihood that a claim might be fraudulent. This helps us to determine eligibility for a policy, the terms of the policy and whether we can provide cover for medical conditions disclosed to us, the price, and whether we can provide you with a monthly credit payment option.

In order to provide you with a price for your insurance policy, the following steps are taken:

• You provide us with data: The first step is that you tell us who you are and what type of insurance you are looking for, e.g. single trip travel insurance for a week in Europe.
• We enrich the data you have provided: Once you have provided us with data, we carry out checks to validate this data (e.g. confirming your identity) and enrich it with data from third party sources. Information on the third party data sources we use is set out above in Types of Personal Information collected. For example, where you declare a pre-existing medical condition we use third party information to assess how much risk the medical condition poses.
• We calculate your insurance risk: We use statistical modelling techniques to assess the data in order to predict the likelihood that a claim will be made and the likely severity of a claim. This assessment is based on various factors including information about the area you are planning to visit. For example, if you are travelling to an area where the cost of medical treatment is high, this may lead to a higher premium. All insurers will use different weightings to price insurance and this is confidential to each insurer.
• Provision of the final price: Once we have a view of your insurance risk we can provide you with a final price, which will include any commission payments and insurance premium tax.

Where you are provided with cover as part of an arrangement with one of our business partners, e.g. your bank, we will not make any automated decisions when your insurance policy starts unless you declare a medical condition. If you declare a medical condition, we may carry out some automated decision making to decide whether we can provide cover, and on what terms, for that medical condition.

Your personalised price may be presented to you in suitable marketing communications, including those sent from price comparison websites or third party partners with whom you have a relationship.

We also make automated decisions throughout the life of your policy, e.g. before offering you a renewal or when dealing with a claim.

Where we make an automated decision using Personal Information which has a legal or substantially similar effect, you have certain rights in relation to that decision. In particular, you have the right to receive meaningful information about the logic involved in relation to the decision, the right to human intervention and the right to obtain an explanation of the decision and challenge it. For more information about this right and how to exercise it please see Data Rights.

We use profiling and other data analysis to build, train and audit our insurance models and algorithms (including those used in our Automated Decision Making) and our machine-learning tools. The models, algorithms and tools we use help us do a number of things including:

• understanding our customers and potential customers better, e.g. how they feel about Aviva, what kind of content or products would be of most use and interest to them, whether they might be displaying characteristics meaning that they may require additional support from us;
• managing claims e.g. determining liability, valuing claims;
• monitoring and improving our services e.g. looking at how to prevent complaints; and
• predicting the likelihood of events arising to assess insurance risk, the likelihood a product will be purchased or to predict if a claim might be fraudulent.

We use a number of data items as described in this Privacy Policy for these purposes. Before we use any such data, we carry out a number of checks including ensuring there are no legal restrictions on using the data under data protection laws, the Equality Act 2010 or under FCA rules and we consider whether use of the data might cause outcomes that are unfairly or unlawfully biased. We then use statistical modelling techniques to assess the data to ensure that the data tells us something meaningful. From time to time, we may share your Personal Information with third parties who provide us with new data which we will test to understand if such new data provides additional understanding.

One technique we may use is natural language processing. Natural language processing is a machine learning tool that involves reading, understanding and analysing speech and text. We may use this tool to help us with the purposes listed above e.g. we may use it to assess how you are feeling about Aviva based on the words that you use to communicate with us.

We may also use profiling and data analysis for other reasons, e.g. to ensure data quality and accuracy and to help us improve our business.

The purpose of this analysis is not to make decisions about you directly, but your Personal Information, in combination with Personal Information relating to other customers, potential customers and/or data provided by third parties, will be used to conduct data analysis so that we can improve our processes, our products and services and check the way our models, algorithms and machine-learning tools work. The Personal Information you submitted to obtain a quote from us may be used for this analysis whether or not you decided to purchase the product.

Where possible, we pseudonymise the data in order to perform this analysis. This means that we remove information from which you can be directly identified, e.g. your name and replace it with a pseudonym or unique identifier. We do this to maximise the security of your information.

We also use profiling in relation to marketing. For further information please see Marketing.

We keep Personal Information for as long as is reasonably required for the purposes explained in this Privacy Policy. We also keep records – which may include Personal Information – to meet legal, regulatory, tax or accounting needs. For example, we are required to retain an accurate record of your dealings with us, so we can respond to any complaints or challenges you or others might raise later. We’ll also retain files if we reasonably believe there is a prospect of litigation. The specific retention period for your Personal Information will depend on your relationship with us and the reasons we hold your Personal Information.

To support us in managing how long we hold your data and our record management, we maintain a data retention policy which includes clear guidelines on data retention and deletion.

If you would like more information about our data retention policy, please contact us.

Sometimes we, or third parties acting on our behalf, may need to transfer Personal Information outside of the UK. We’ll always take steps to ensure that any transfer of Personal Information outside the UK is carefully managed to protect your privacy rights and ensure that adequate safeguards are in place. This might include transfers to countries that the UK considers will provide adequate levels of data protection for your Personal Information (such as countries in the European Economic Area) or putting contractual obligations in place with the party we are sending information to. Transfers within the Aviva group will be covered by an agreement entered into by members of the Aviva group (an intra-group agreement) which contractually obliges each group company to ensure that your Personal Information receives an adequate and consistent level of protection wherever it is transferred within the group.

For more information about data transfers and the safeguards we have put in place, please contact us.

We may use Personal Information to send you direct marketing communications about our products and services that we feel you’ll be interested in. This may include marketing relating to products offered by other brands or companies within the Aviva group (such as quotemehappy, Wealthify and Succession Wealth) as well as communications about promotions and prize draws.

Marketing communications may be sent by email, post, SMS, telephone and push notification. You may also see display advertising on websites, mobile applications, social media, television or in online search results.

You have control over our use of your Personal Information in relation to marketing communications. You can:

• ‘Opt out’ of receiving direct marketing. When you register with us, request an online quote, or purchase a product or service you will be given the opportunity to opt out. In addition, our email, post, SMS and telephone marketing communications include information to help you manage your marketing preferences;
• Change your marketing preferences at any time by e-mailing us at contactus@aviva.com or writing to us at Aviva, Freepost, Mailing Exclusion Team, Unit 5, Wanlip Road Ind Est, Syston, Leicester, LE7 1PD. If you are registered for MyAviva you can change your marketing preferences at any time from within your account.

Please note that opting out of one type of marketing, e.g. by email or telephone, doesn’t mean you will be opted out of all marketing. Bear this in mind when you manage your preferences. You can always contact us directly if you would like us to stop all forms of direct marketing.

We try to limit marketing and only send you offers and promotions that you might be interested in, based on Personal Information we have about you and profiling that we have carried out (further details can be found under the sub-heading ‘Marketing profiles’ below). We may use information provided by third parties to send you direct marketing and we may use your Personal Information to send other people direct marketing, e.g. people you live with.

Please remember that if you opt out of receiving marketing, we will still send you communications relating to your products. If you choose to opt out of tailored offers and advertising, you may still see generic advertising displayed online and in MyAviva, it just might not be as relevant to you.

Cookies and similar technologies

We rely on third-party advertising technology (such as the deployment of cookies or small text files on our website or pixels within emails) to collect information about you. This technology is used to optimise what you may see on our websites and deliver content when you are browsing elsewhere. We may also collect information about your use of other websites. We do this to provide you with advertising that we believe may be relevant for you, as well as to improve our own products and services.

For further information about cookies and other technologies we use on our website and how to manage cookies, please see our Cookie Policy.

Social media and online platforms

We share Personal Information with media agencies and social media and other online platforms to help us target our online marketing. Social media and other online platforms may also use Personal Information they hold and combine it with Personal Information received from us to create target audiences. These are audiences that we think would be interested in our online advertising. This may involve social media and other online platforms building a ‘lookalike’ profile of the type of person we are trying to target and providing specific adverts to those people when they browse the internet or use social media.

If we use or share Personal Information with third parties in order to send you direct marketing, we will respect the marketing preferences you have set. We recommend you routinely review the privacy notices and preference settings that are available to you in MyAviva and any online platforms and smart devices you use as they will dictate how adverts and other messages are displayed and shared across those platforms.

Marketing profiles

We use automated processes to help us provide more personalised marketing of our products. To do this, our automated process creates a marketing profile for you using information such as:

• identification data;
• behavioural data (e.g. data relating to your use of our website);
• your gender and age;
• contact data;
• status data (e.g. number of children in household);
• product related data (e.g. policy identifiers, renewal dates);
• details of our interactions with you;
• device and vehicle-related data.

Our process analyses this data to determine the most relevant products, services, offers or benefits to offer you and to decide the appropriate time and channel for offering them to you.

Information obtained in relation to one product may be used in relation to marketing other products from the Aviva group.

We may also create profiles using your Personal Information together with information relating to other individuals, we use these profiles to decide what marketing may be of interest to individuals with similar characteristics to you.

Promotions and prize draws

We occasionally run promotions and prize draws for our customers and third parties. Our communications to you about these promotions before you enter them are marketing. If you opt out of receiving direct marketing, you will not receive communications about promotions and prize draws.

We may use your Personal Information to select you as a winner, inform you of promotion outcomes and send prizes to your nominated address. We may use third party fulfilment partners to assist us in administering promotions, including contacting you on our behalf. In accordance with the rules of the Advertising Standards Authority, we may publish or make publicly available information that indicates that a valid award has taken place. If we do this, only your surname, country and, if applicable, your winning entry, will be published. You have the right to object to this use of your Personal Information.

You have legal rights under data protection laws in relation to your Personal Information. Read below to learn more about each right you may have.

We may ask you for proof of identity when you make a request to exercise any of these rights. We do this to ensure we only disclose information to the right individual.

We aim to respond to all valid requests within one month. It may take us longer if the request is particularly complicated or you have made several requests. We’ll always let you know if we think a response will take longer than one month. We may also ask you to provide more detail about what you want to receive or are concerned about.

We may not always be able to do what you have asked. This is because your rights will not always apply, e.g. if it would impact the duty of confidentiality we owe to others, or if the law allow us to deal with the request in a different way. We will always explain to you how we are dealing with your request. In some circumstances (such as the right to erasure or withdrawal of consent), exercising a right might mean that we can no longer provide our product to you.

For further information about or to exercise any of your rights, please contact us. If you wish to make a subject access request, please fill out this form.

Your rights are as follows:

If you have any questions about this Privacy Policy or how to exercise your rights, please contact our Data Protection Officer:

Write to: The Data Protection Team, Aviva, PO Box 7684, Pitheavlis, Perth PH2 1JR

Email us: DATAPRT@aviva.com

If you'd like to submit a subject access request, please fill out this form or write to us at the above address.

If you’re not happy with the way we’re handling your Personal Information, you have a right to make a complaint with your local data protection supervisory authority at any time. In the UK this is the Information Commissioner's Office (ICO). We ask that you please attempt to resolve any issues with us before contacting the ICO.

This Privacy Policy is updated from time to time to take account of changes in our business activities, legal requirements and to make sure it’s as transparent as possible, so please check back here for the current version. You can see when this Privacy Policy was last updated by checking at the top of this page.