INFORMATION WE MAY COLLECT
Personal data means any information about an individual person from which that person can be identified. It does not include data where the identity has been removed, i.e. 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 (for each traveler) first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, age(s) or date(s) of birth, passport number, nationality, and country and/or state of residency.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details relating to or necessary for the provision of products and services you desire to or have purchased from us, such as coverage limits, dates of travel, trip deposit date (if applicable), destination, trip type (e.g., pleasure, adventure, business), and booking and/or tour operators.
Technical Data includes internet protocol (IP) address, 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 our Site.
Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Site and Services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. This also includes us making a note of conversations we have had with you in person and/or communications you sent to us. This helps us to manage our relationship with you and ensures you only receive communications from us that are relevant and timely.
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 information 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 an insurance quote or policy). 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 WE COLLECT YOUR DATA
We collect different information about you in a number of ways:
Information you give us
When you obtain a policy quote or buy a policy, sign up for our marketing communications, contact us to ask a question or give us feedback, we will store the personal data you give to us such as your name, email address, postal address, telephone number, and other details. We will also keep a record of our communications with you (including information like your survey responses).
Automated technologies or interactions
As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Information from third parties
We may receive information about you from third parties as set out below:
- Analytics providers such as Google
- Advertising networks such as Facebook or Quora
- Search information advertising providers such as Google AdWords
HOW WE MAY USE YOUR INFORMATION
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:
- Where we need to perform the contract we are about to enter into or have entered into with you (i.e., when we help you purchase an insurance policy).
- 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.
- Where we have your explicit consent before using your personal data in that specific situation. However, generally we do not rely on consent as a legal basis for processing your personal data and you have the right to withdraw consent to marketing at any time by contacting us (or by using any other mechanism we provide, such as an unsubscribe link in an email). You will find the relevant contact details at the end of this policy.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Finally, while the table below describes our practices, we do not use any personal data (in any of the categories we have identified) relating to individuals in the European Economic Area for any marketing communications or advertising unless such individuals have opted in to receive marketing communications or advertising from us.
|Purpose/Activity||Type of Data||Lawful Basis for Processing Including Basis of Legitimate Interest|
|To provide you with a quote for an insurance policy or answer questions about the potential purchase of an insurance policy|| ||Performance of a contract with you|
|To process and deliver your purchase of an insurance policy including: || || |
|To manage our relationship with you which will include: || || |
|To enable you to complete a survey|| || |
|To administer and protect our business, the Services and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|| || |
|To deliver relevant Services and Site content, product offerings, and advertisements to you and measure or understand the effectiveness of the advertising we serve to you|| ||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Site and Services, product offerings, marketing and communications with you, customer relationships and experiences|| ||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site 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|| ||Necessary for our legitimate interests (to develop our products/services and grow our business)|
Fulfilling Quote Requests or Policy Purchases
The information collected for a quote or for an insurance policy is used to provide policy quotes and to issue your policy. This information is sent only to the insurance company underwriting the policy and/or the insurance companys administrator (a company the insurance company engages to manage the administration of certain of their insurance products).
When we collect information for a quote or an insurance policy, we will use it only in connection with the provision of the quote and/or delivering, billing for, and communication concerning the relevant insurance policy or policy application, including (where applicable) allowing you to use a customer portal on visitorscoverage.com to access information regarding the relevant insurance policy or policy application.
We retain information provided by you for the provision of a quote or purchase of an insurance policy on our servers located in the United States.
We may use personal data in order to display custom, personalized content to our visitors and send newsletters, emails, features, promotional material, surveys and other updates to our users. We may extend offers to users on behalf of our partners about a particular product or service that may be of interest to you, but we will never give out personal data in a form identifiable to you for those purposes without your permission. You may, at any time, opt out of receiving such communications by contacting us (or by using any other mechanism we provide, such as an unsubscribe link in an email).
Other Disclosures or Uses
We may disclose personal data to trusted third party vendors working for us in connection with the operation of our Site and Service and our business, so long as those parties agree to use this information only to provide services to us, and to keep this information confidential.
We reserve the right to use or disclose any information as needed to satisfy any law, regulation or legal request (e.g., subpoenas or search warrants), to conduct investigations of consumer complaints or possible breaches of law, to protect the integrity of our Website and our property, or to protect the safety or fundamental rights of our visitors or others.
Personal data, may be transferred to a third party if there is a transfer of the assets or ownership of VCI or if VCI files for bankruptcy.
Some of our Website pages may contain electronic images known as Web beacons, which are also called single-pixel gifs. These images allow us to count users who have visited those pages and to deliver co-branded services. We also may include Web beacons in promotional e-mail messages or newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your personal data but they are a technique we use to compile aggregated statistics.
We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. Presently, the only third-party analytics service provider we use is Google Analytics. While Google Analytics may collect personal data to derive the information that it shows to us, we cannot view Google Analytics information identifiable to you.
For Googles privacy practices see http://www.google.com/analytics/learn/privacy.html.
If you prefer, you can change your browser settings to have your browser provide a warning each time a cookie is being sent, you can choose to turn off only third party cookies (that is, cookies that are placed by a domain other than visitorscoverage.com or whatever domain youre currently viewing), or you can choose to turn off all cookies. If you turn cookies off, many elements of the Service, like most websites, may not function properly.
You may also disable Web beacons by disabling HTML images in your email program, which may also affect other images in emails you receive.
To opt out of data recording and analysis by Google Analytics, see https://tools.google.com/dlpage/gaoptout.
EXTERNAL LINKS AND THIRD PARTIES
Some of the pages and section uses frames, external interfaces and external links wherever necessary to effectively present the information for your convenience, so you can get the necessary information and apply for a specific insurance plan online, without leaving visitorscoverage.com.
We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act). We do not knowingly collect or process any information from anyone under 13 years of age (16 in the EU). Our Site and Service is directed to people who are at least 13 years old or older (16 in the EU). However, we will collect and process personal data about children under 13 years of age (16 in the EU) when submitted by a parent, guardian or other appropriate adult for the purposes of obtaining a quote for, or purchasing, an insurance policy covering such children.
DO NOT TRACK
Your personal data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If youre located outside the United States and choose to provide your personally identifiable information to us, we may transfer your personal data to the United States and process it there.
If you use your credit or debit card to purchase a policy through us, the payment information is transmitted directly to the insurance company providing the policy. We do not receive that information. The insurance companies we work with process payment information securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). You can find more information about this standard here: https://www.pcisecuritystandards.org/pci_security/.
We offer the use of a secure server for visitorscoverage.com. All personally identifiable information supplied by you to us via visitorscoverage.com is transmitted via Secure Socket Layer (SSL) or similarly secure technology. We allow personally identifiable information to be accessed only by persons with specified rights to do so.
You should be aware that if you voluntarily disclose information in visible forum online (whether through VCI's services or any other services available online), personal or otherwise, that information could be collected and used by others. For example, if you use chat forums, bulletin boards, and you post your e-mail or id, you may receive unsolicited messages form others. VCI has no control over this use of your personal data.
Due to the open nature of communication through the Internet, we cannot guarantee that communications between you and VCI, or between VCI and the insurance carriers to which you ask us to submit your information, will be free from unauthorized access by third parties, nor that third parties will not be able to circumvent the safeguards we have put in place. We cannot absolutely guarantee the security of any information that is disclosed or transmitted online.
We will only retain your personal data for as long as necessary to fulfill 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 unauthorized 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.
YOUR RIGHTS AND CONTROLLING YOUR PERSONAL DATA
Under the applicable laws of various countries, you may have certain rights concerning your personal data, such as under EU law, the right to access to, rectification or erasure of, and/or suspension or restriction of, or objection to, processing of your personal data, and the right to data portability. If you have any questions or want to exercise any of your rights with respect to your personal data, please contact us by the methods indicated at the end of this section.
Exercising Your Rights
Before we process any request, we may request personal data to verify your identity where allowed by law, and to verify any new or corrected information you may provide. You will not usually 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.
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.
To exercise your rights with respect to your personal data or otherwise ask us about our collection and processing of your personal data, use ourcontact us form.
Last updated May 25, 2018