How we use your personal information

Your information will be held by International Passenger Protection Limited (IPP) which is a privately owned insurance intermediary and Lloyd’s coverholder.

How we use your personal information

IPP is a cover-holder of Liberty Mutual Insurance Europe.This privacy notice is to let you know how we promise to look after your personal information.This includes what you tell us about yourself, what we learn by having you as a customer and the choices you give us about what marketing you want us to send to you.This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

• To keep your data safe and private
• Not to sell your data

Data Protection law changed on 25 May 2018

How the law protects you

As well as our Privacy Promise, your privacy is protected by law.This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside IPP. The law says we must have one or more of these reasons:

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When it is in our legitimate interest, or
• When you consent to it

A legitimate interest is when we have a business or commercial reason to use your information.But even then, it must not unfairly go against what is right and best for you.If we rely on our legitimate interest, we will tell you what that is.

Here is a list of all the ways we may use your personal information, and which of the reasons we rely on to do so.This is also where we tell you what our legitimate interests are.

What we use your personal information for	Our reasons	Our legitimate interest
To manage our relationship with you To develop new ways to meet our customers’ needs To provide guidance about our products and services	Your consent Fulfilling contracts Our legitimate interests Our legal duty	Keeping our records up to date Seeking your consent when we need it to contact you Being efficient about how we fulfil our legal duties
To develop and manage our brands, products and services	Fulfilling contracts Our legitimate interests Our legal duty	Developing products and services Being efficient about how we fulfil our legal and contractual duties
To deliver our products and services To make and manage customer payments	Fulfilling contracts Our legitimate interests Our legal duty	Being efficient about how we fulfil our legal and contractual duties Complying with regulations that apply to us
To detect, investigate, report and seek to prevent financial crime To manage risk for us and our customers To obey law and regulations that apply to us To respond to complaints and seek to resolve them	Fulfilling contracts Our legitimate interests Our legal duty	Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect. Complying with regulations that apply to us Being efficient about how we fulfil our legal and contractual duties
To run our business in an efficient and proper way.This includes managing our financial position, business capability, planning, communications, corporate governance and audit.	Our legitimate interests Our legal duty	Complying with regulations that apply to us Being efficient abut how we fulfil our legal and contractual duties.
To exercise our rights set out in agreements or contracts	Fulfilling contracts

Where we collect personal information from

We may collect personal information about you from these sources:

Data you give to us:

• When you apply for our products and services
• When you talk to us on the phone
• When you use our website
• In e-mails and letters
• In claims forms and other documents

Who we share your personal information with

• H.M. Revenue & Customs, regulators and other authorities
• Fraud prevention agencies
• Liberty Mutual Insurance Europe who are our underwriter and details of their privacy policy is available at:
  http://www.libertyspecialtymarkets.com/privacy-cookies/
• In respect of claims only - Sedgwick who are our claims handlers and further details of their privacy policy is available at: https://www.sedgwick.com/global-privacy-policy

How long we keep your personal information

IPP may keep your data for up to 10 years for one of these reasons:

• To respond to any questions or complaints
• To show that we treated you fairly
• To maintain records according to rules that apply to us

We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.

How to get a copy of your personal information

You can access your personal information we hold by writing to us at this address:

Compliance Officer

International Passenger Protection Limited

IPP House

22-26 Station Road

West Wickham

KentBR4 0PR

Or by e-mail at:

info@ipplondon.co.uk

Letting us know if your personal information is incorrect

You have the right to question any information we have about you that you think is wrong or incomplete.Please contact us if you want to do this.

If you do, we will take reasonable steps to check its accuracy and correct it.

What if you want us to stop using your personal information?

You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it.This is known as the “right to object” and “right to erasure” or the “right to be forgotten”.

There may be legal or other official reasons why we need to keep or use your data.But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data.This means that it can only be used for certain things, such as legal claims or to exercise legal rights.In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:

• It is not accurate
• It has been used unlawfully but you do not want us to delete it
• It is not relevant any more, but you want us to keep it for use in legal claims
• You have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data or ask us to delete it or restrict how we use it, please contact us.

How to withdraw your consent

You can withdraw your consent at any time.Please contact us if you want to do so.

How to complain

Please let us know if you are unhappy with how we have used your personal information.You can contact us by writing to:

Compliance Officer

International Passenger Protection Limited

IPP House

22-26 Station Road

West Wickham

KentBR4 0PR

Or via e-mail:

info@ipplondon.co.uk

You also have the right to complain to the supervising authority (ICO).

You can report a concern by either visiting their website at https://ico.org.uk and start a Live Chat under their “Report a Concern” tab or by calling their Helpline on 0303 123 1113