PRIVACY NOTICE
We care about your personal data
Assured Travel Solutions Ltd, (ATS) using the trading style of DelayOK (“we, “us” “our”), is authorised and regulated by
the Financial Conduct Authority in the United Kingdom to provide insurance
products and services. Protecting your privacy is a top priority for us. This
notice explains how and what type of personal data will be collected, why it is
collected and with whom it is shared. Please read this notice carefully.
1.Who is the data
controller?
A data controller is the individual or legal person who
controls the use of the data and is responsible for keeping it safe. The laws
apply to personal data in both paper and electronic files. Assured Travel Solutions Ltd is the data controller as defined by relevant data
protection laws and regulations.
2.What personal data will be collected?
Depending on the type of insurance product or
service we provide to you, we will collect and process various types of
personal data about you:
•
Surname, first name
•
Address
•
Place of residence
•
Date of birth
•
Gender
•
Telephone numbers
•
Email address
•
Credit/debit card and bank account details
•
CCTV images (we may collect this if you visit one of
our offices)
•
Location / GPS information
•
Passport Number
Some of which may be required for fraud detection
purposes.
3.How will we
obtain and use your personal data?
We will collect and use the personal data that you provide to us and
that we receive about you for a number of purposes. We
provide more information in the following table:
|
The administration of products (for example, sending details of cover,
underwriting, handling claims,)
|
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Fraud prevention and detection
|
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To administer debt recoveries
|
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To meet any legal obligations (for example, regulatory, tax, accounting and administrative obligations)
|
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To redistribute risk by means of reinsurance and co-insurance
|
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To enhance, modify, personalise, or otherwise improve our services/
communications for the benefit of our customers
|
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To enhance the security of our networks and information systems
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To better understand how people interact with our websites
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To determine the effectiveness of promotional campaigns and
advertising
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From time to time, we may wish to
inform you, or permit Assured Travel Solutions group companies and selected
third parties to inform you about products and services that we feel may be of
interest to you in accordance with your marketing preferences. However,
we can only do this with your express written consent or on
the basis of Legitimate Interests. You can change your mind about this
at any time by contacting us as set out in section 10 below.
We will process personal data we
receive about you from third parties such as brokers and business partners, insurers and fraud prevention agencies.
We will process your personal data
where it is necessary for us to comply with our contractual obligations to you,
or where we need to take pre-contractual steps at your request.
We will process your personal data where necessary
for the purposes of our legitimate interests. “Legitimate interests” means the
interests of our company in conducting and managing our business to enable us
to give you the best service/products and the best and most secure experience.
For example, we may process your information to invite you to renew your policy
upon expiry or protect you against fraud when transacting on our website and to
ensure that our websites and systems are secure. When we process your personal
information for our legitimate interests, we make sure that we consider and
balance any potential impact on you and your rights under data protection laws.
Our legitimate business interests do not automatically override your interests
– we will not use your personal data where our interests are overridden by the
impact on you (unless we are required or permitted by law).
We will need your personal data and use it for the
purposes described above if you would like to buy our products and
services. If you do not wish to provide this to us, we may not be able to
provide the products and services to you.
CCTV cameras are in operation at our offices for
health and safety, prevention of crime and prevention of damage to our building
and company assets. We may collect video recordings and still pictures which
feature you, if you are in the field of vision of any of our CCTV system. These
images are only held for a period of ninety days.
4.Who will have
access to your personal data?
We will ensure that your personal
data is processed in a manner that is compatible with the purposes indicated
above.
For the reasons stated above, your
personal data may be disclosed to the following parties who operate as third party data controllers depending on the type of policy
you have bought from us:
- Other ATS group
companies, industry governing bodies, regulators, insurers, fraud
prevention agencies and claims databases, for underwriting and fraud
prevention purposes;
- Retailers of insured products;
For the reasons stated above, we may
also share your personal data with the following who act as data processors
under our instruction:
- Other ATS group
companies; experts such as technical consultants, lawyers
and loss adjustors; repairers; ticket sellers; service companies to
discharge operations (claims, IT, postal, document management); and
- Advertisers and
advertising networks to send you marketing communications, as permitted
under local law and in accordance with your communication
preferences. We do not share your personal data with non-affiliated
third parties for marketing purposes without your permission.
Finally, we may share your personal
data in the following instances:
- In the event of any
contemplated or actual reorganization, merger, sale, joint venture,
assignment, transfer or other disposition of all or any portion of our
business, assets or stock (including in any
insolvency or similar proceedings); and
- To meet any legal
obligation, including to the Financial Ombudsman Service if you make a
complaint about the product or service we have
provided to you.
5. Where will
your personal data be processed?
Your personal data may be processed
both inside and outside of the United Kingdom (UK) and the European Economic
Area (EEA) by the parties specified in section 4 above, subject always to
contractual restrictions regarding confidentiality and security in line with
applicable data protection laws and regulations. We will not disclose
your personal data to parties who are not authorised to receive it.
Whenever we transfer your personal
data for processing outside of the UK and the EEA to another ATS group company,
we will do so on the basis of ATS’s approved binding
corporate rules known as the ATS Privacy Standard which set out our commitment
to maintain the same high level of protection for personal information
regardless of where it is processed. We will take steps to ensure that the
transfer of your personal data outside of the UK and the EEA receives the same
level of protection as it does in the UK and the EEA.
6. What are your
rights in respect of your personal data?
Where permitted by applicable law or regulation, you
have the right to:
·
Access the personal data held
about you and to learn the origin of the data, the purposes and ends of the
processing, the details of the data controller(s), the data processor(s) and the
parties to whom the data may be disclosed;
·
Withdraw your consent at any
time where your personal data is processed with your consent;
·
Update or correct your personal
data so that it is always accurate;
·
Delete your personal data from
our records if it is no longer needed for the purposes indicated above;
·
Restrict the processing of your
personal data in certain circumstances, for example where you have contested
the accuracy of your personal data, for the period enabling us to verify its accuracy;
·
Obtain your personal data in an
electronic format for you or for your new insurer; and
·
File a complaint with us and/or
the Information Commissioner’s Office.
You may exercise these rights by contacting us as
detailed in section 10 below.
7. How can you object to the processing of your personal data?
You have the right to object to us processing your personal data or tell
us to stop processing it (including for purposes of direct marketing). Once you
have informed us of this request, we shall no longer process your personal data
unless permitted by applicable laws and regulations.
You may exercise this right in the same manner as for your other rights
indicated in section 6 above.
8. How long do we keep your personal data?
We will retain your personal data for a maximum of seven
years from the date the insurance relationship ends. If we are
able to do so we will delete or anonymise certain areas of your personal
data as soon as that information is no longer required for the purposes for
which it was obtained.
9. Automated decision making, including profiling
We may use automated decision making, including profiling, to assess insurance
risks, detect fraud, and administer your policy. This helps us to decide
whether to offer the insurance and determine prices.
For example, when you buy a travel
insurance product, we carry out automated decision making. We may accept or
reject a potential policyholder for cover based on their residence. We do not
offer insurance for customers who are not resident in the UK.
If you have any concerns regarding
the decision reached, please let us know at the contact details set out in
section 10 below and we will arrange for a person to check the accuracy of the
result.
10. How can you contact us or make a complaint?
If you have any queries or concerns about how we use
your personal information, you can contact or make a complaint to us as
follows:
·
By post: Data Protection
Officer, Assured Travel Solutions Ltd, Bath House, 6-8 Bath Street,
Bristol, United Kingdom, BS1 6HL
·
By telephone: 03332416630
·
By email: contact@delayok.com
We will need details of your name, email address,
policy number, and purpose of your request.
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
11. How often do we update this privacy policy?
We regularly review this privacy
notice. This privacy notice was last updated in January 2025.