Your privacy is important to AllClear and we are committed to respect and protect your privacy and your personal information. The following describes our policies for collecting, protecting, and disclosing your personal information and how we comply with relevant legislation including the Data Protection Act 2018 (UK), the EU General Data Protection Regulation and the Privacy Act 1988 (Cth).
Who we are
AllClear is a travel insurance intermediary specialising in providing tailored travel insurance.
We are classed as a Data Controller which means we are responsible for deciding how your personal data will be processed.
How we collect your personal information
We collect personal information that is necessary for our business activities and in order to provide and develop our services. We may do this in a number of ways, including:
- Directly from you, when you provide it to us or our agents, partners, service providers or contractors;
- From publicly available resources;
- By analysing our own records of your use of our services and website;
- Third parties who you have asked to provide your personal information to us;
- People who are involved in a claim or assist us in assessing, investigating, processing or settling claims, including witnesses, medical service providers, external claims data collectors and verifiers; and
- Law enforcement, dispute resolution, statutory and regulatory bodies
More information about how we collect your personal information appears below.
Automated Decision Making and Profiling (website only)
Our on-line Quote and Buy systems carry out automated decision making and profiling to decide whether we can provide insurance to you and at what price. If you do not want your data to be processed in this manner then you are able to obtain quotations and arrange insurance via our Contact Centre.
Passive Collection (website only)
The sole purpose of passively collecting your information is to improve your experience when using our websites and services.
Information we collect
We collect your personal information and use it in the following ways:-
Servicing Your Insurance
We collect and use your personal information to provide a travel insurance quotation and to arrange and administer your insurance. This information may also include sensitive (special category) data such as your medical history and conditions which we can collect for insurance purposes without your specific consent as it is required to provide you with a quotation and/or arrange your insurance. If you give us information about another person in doing so you are confirming that you have their permission to do so and that we may use their personal data in the same way as we will use yours. We will only use this information to provide you with the service that you signed-up for.
When your insurance is due to expire we will contact you by telephone, letter and/or email to remind you that your policy is due for renewal.
In certain instances, we may request data from you, e.g. in the form of a customer survey, to better understand how travel insurance is used and our service could be improved. We would always inform you if this information is to be shared with a third party, and you would have the choice to participate or not. All data would be anonymised.
We also use and disclose your personal information for the following purposes:
- Verifying your identity;
- Facilitating provision of our products and services to you (including facilitating a claim or an assistance matter);
- Processing claims, including assessing and investigating claims and engaging service providers to assist us to process, assess, investigate and manage claims;
- Addressing or responding to any requests from you;
- Developing and improving the quality and scope of the products and services we provide, and seeking your feedback;
- Handling complaints and disputes;
- Detecting, investigating and preventing fraud;
- Conducting business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
- Updating our records and keeping your contact details up to date;
- Complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or co-operating with any governmental authority
We also ask your permission to add you to our marketing list so we can send you details of special offers and new product information from carefully selected partners and our associated companies.
If you have agreed to be added to our marketing list we may contact you by email, text, telephone, mail or other agreed means.
We will not share your marketing information with any other third parties and we always provide you with the means to opt-out of receiving this material.
We will not sell or trade your information or your personal data to other companies.
What other kinds of personal information do we collect and hold?
In addition to the kinds of personal information specified above, we may also collect the following kinds of personal information about you:
- Mailing and street addresses;
- Email address;
- Phone numbers;
- Profession, occupation or job title;
- When you access our websites, information about your computer or mobile device including its model and IP address;
- Your transaction history with us, including in respect of your purchases and participation in competitions or promotions relating to any of the brands we represent;
- Other personal information you voluntarily provide to us during the course of transacting with us, when making inquiries about our products or services, or when providing details about a claim or a complaint, such as your medical conditions and their status
If you apply for employment with us, we may also collect information about your educational qualifications, employment history and membership of trade unions or professional associations.
What happens if you do not provide your personal information to us?
If you do not provide personal information that we request or require in connection with our business functions and activities, we may not be able to provide some or all of our products or services to you, or be able to process a claim, or be able to respond and assist in the manner required. For example, we may not be able to provide you with insurance, or contact you. We also may not be able to provide you with information about products and services that you may want. If you are applying for employment with us, we may be unable to fully consider your application.
Information we share – with insurers and underwriters
Your information will be shared with insurers, underwriters and other companies for the purpose of arranging and administering your insurance. Your information may be disclosed to regulatory bodies for monitoring or enforcing insurance rules and regulations. To prevent and detect fraud we and the insurer may share information with other organisations and public bodies including the police.
Any new information you may disclose during the claims and assistance process may be shared with us, or our related companies, within the group, or required in the provision of services for you.
We may disclose your personal information in certain circumstances, such as where we are required or authorised by law or where you have consented to us doing so.
We also may disclose your personal information to:
- Our employees, related bodies corporate, contractors or service providers or commercial partners for the purposes of operating our website or our business, fulfilling requests by you, and to otherwise provide services to;
- Loss adjusters, investigators and other service providers to assist us to process, assess, investigate and manage claims;
- Reinsurers who assist us to manage our risks and business;
- Others in accordance with a request made by you;
- Our related companies and business partners and commercial partners;
- Persons engaged in providing us with professional, business, technology and corporate services, when reasonably required (including web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants)
Less commonly, we may use or disclose your personal information where it is reasonably necessary:
- To assist in locating a missing person;
- To establish, exercise or defend a legal or equitable claims;
- For the purpose of a confidential alternative dispute resolution,
- Or on other grounds permitted by applicable law
Other third parties
AllClear uses a variety of services hosted by third parties such as Google Analytics, Bing Ads, Google Tag Manager, Live Chat, TrustPilot and YouTube. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP address. For information on how third parties collect and use your information, please refer to their privacy policies. By using AllClear, you consent to the processing of data by these third parties in accordance with their privacy policies.
If you use our webchat service then we will share your information with our Service Provider “Live Chat” for the purposes of helping you with your query.
You have the following rights in respect of your personal information:
- To know how we will process your personal data (this notice);
- To have a copy of your data that we hold (normally free of charge);
- To have the data corrected if it is inaccurate or incomplete;
- To have the data deleted if there is no compelling reason for us to continue to process it;
- To ask us to stop processing your data in certain circumstances;
- To ask us to provide your personal information in a portable format so that you can reuse your data across different services (this is subject to certain conditions);
- To ask us to provide information on automated decision making and profiling
Overseas disclosure of personal information
Depending on which country you live in, we usually hold your personal information in computer systems controlled by us in the UK.
We may transfer your personal information to recipients in other countries for the purposes of providing you with services or for the purposes of our business operations or to enable our service providers to provide services to us. The recipients may include our related companies, reinsurers, our IT service providers and other service providers such as loss adjusters and investigators.
Those overseas recipients are located in Australia, the Philippines, Spain, Gibraltar, the USA and the UK. Your personal information may also be disclosed to entities and parties in the countries, regions nominated under your insurance policy, or any other regions where you may require assistance.
Access and correction of your personal information
You have the right to access your personal information which we hold about you, subject to some exceptions. Before we provide you with access to your personal information we may require some proof of identity. We will not charge you for simply making a request. If you wish to access the personal information we hold about you, please contact us using the contact details provided below.
You also have the right to request that we correct any inaccurate personal information we hold about you, subject to some exceptions under applicable laws. If you wish to correct the personal information we hold about you, please contact us using the contact details provided below.
When contacting us to request access to or correction of any personal information we hold about you, we ask that you provide us with as much detail as you can about the information in question as this will help us to retrieve it.
If we do not agree to your request to provide you with access to your personal information or to amend your personal information, we will inform you of our decision within a reasonable period. If you wish to complain about this outcome or to attach a statement to your record that you believe the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, please see our complaints procedure below.
You may request further information about the way we manage your personal information, or lodge a complaint if you believe that we have breached your privacy, by contacting our Privacy Officer using the contact details below.
We will deal with any complaint by investigating it, and providing a response to you within a reasonable time, provided that we have all necessary information and have completed any investigation required. In some cases, we may need to ask you to put your complaint in writing so that we are sure that we understand it, and may also need to ask you for further information or to verify your identity. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will treat your complaint confidentially and respond to you within a reasonable time, usually in writing.
If you are dissatisfied with the outcome, please contact us. Alternatively, you may take your complaint to the Office of the Australian Information Commissioner. Contact details Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001. Tel: 1300 363 992. Web: www.oaic.gov.au
If you believe that we have interfered with your privacy in our handling of your personal information or if you have any questions about our processes for handling your information, you may send your queries or lodge a complaint by contacting us on the below contact details:
Privacy Queries & Complaints,
AllClear Travel Insurance Services Pty Ltd
Suite 1.04, Level 1, 19 Harris Street
Pyrmont, 2009 Sydney NSW
We will only retain data for as long is necessary and in line with our data retention policy. In most cases this will be a maximum of 7 years from the expiry of an insurance contract.
Linked websites and information security
We are committed to protecting the privacy of our customers and of visitors to our website. We have implemented security policies, rules and technical measures to protect your personal data from unauthorised access; improper use or disclosure; unauthorised modification; and unlawful destruction or accidental loss.
All personal information you provide to us is stored on secure servers. We use a variety of technical and organisational security techniques, including encryption and authentication, to help with the protection and maintain the availability, security and integrity of your personal information.
We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed or when we are no longer required by law to retain it (whichever is the later).
We do not collect, store or have access to your credit card details. When you use a credit card to make a purchase, the details are transmitted directly to a third party payment processor who arranges the transfer of funds from your bank account to our bank account.
We are committed to protecting your information through the following measures:
- Restricting access to your personal information to only those who need to use it for the relevant purpose;
- Transferring your personal information only in encrypted form;
- Preventing unauthorised access to IT systems by using firewalls;
- Permanent monitoring of IT systems to detect and stop misuse of personal information
If you contact us by email you should be aware that emails are not secure unless they have been encrypted. We cannot accept any responsibility for the unauthorised access to your data that is beyond our control.
The Privacy Officer
AllClear Insurance Services PTY Limited
Suite 1.04 Level 1,
19 Harris Street,
Alternatively, you can email us at firstname.lastname@example.org or you can call us on 1800 31 29 61.