Privacy Policy

Introduction

This is the Savvy privacy notice. Savvy is a trading brand name of Acumen Insurance Services Ltd.

Acumen Insurance Services Ltd manages and administrates your data to perform its obligations under your contract when you purchase an insurance policy with Savvy. Acumen Insurance Services Ltd is the controller and responsible for your personal data collectively referred to as Acumen Insurance Services Ltd, "we", "us" or "our" in this privacy notice.

1. Important Information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Acumen Insurance Services Ltd collects and processes your personal data through your use of this website and purchasing travel insurance with us, including sign up to our newsletter, purchase of a travel insurance product or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and it not intended to override them.

Controller

Acumen Insurance Services Ltd is made up of different brands and Savvy is one of them. In most cases, Acumen Insurance Services Ltd will be the controller of your data and will do its utmost to protect the data provided by you. Please read the privacy policy to understand how your personal data is being processed. We will let you know how we use your data. Acumen Insurance Services Ltd is the controller and responsible for this website.

Contact details:

Our full details are

Full name of legal entity: Acumen Insurance Services Ltd (Registered in England No. 05004926)

Title: Data Protection Officer

Email address: Dataprotection@cspinsurance.com

Postal address: Acumen Insurance Services Ltd, St Clare House, 30-33 Minories, London EC3N 1PE

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contract in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

This version was last updated on 17th September 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (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 first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, postal address, email address and telephone numbers.
Financial Data includes bank account and payment card details to purchase a policy. Financial data will be encrypted accordingly.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, 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 this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Health and Medical Information includes medical history obtained from you.

We may collect Special Categories of Personal Data about you. This could be in relation to your health in which we will obtain your medical history and medical data in order to calculate your premium and process your purchase with Acumen Insurance Services Ltd.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by purchasing travel insurance products either through our contact centre or through our website online, including correspondence with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
- Create an account on our websites;
- Subscribe to our service or publications;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey; or
- Give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
  - Analytics providers such as Google based outside the EU.
  - Advertising networks such as Affiliates based in the UK.
  - Search information providers
- Identity and Contact Data from data brokers or aggregators within the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

You have the right to withdraw consent to marketing at any time by contacting us.

4. Purpose for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. On the basis we use your personal data under the grounds of Legitimate Interests we will compile and record a Legitimate Interest Assessment to protect your rights and freedoms.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 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.

Purpose	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or for you to receive a quote	Identity Contact Health and Medical Information Financial	Performance of a contract with you
To process and deliver your product and services including: Collecting medical data Providing medical assistance abroad Claims handling Manage payments, fees and charges	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) Consent
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	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 website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website 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	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established methods to provide you an option to make a decision whether you would like to receive marketing materials. If you would like us to stop sending certain or any marketing materials you may opt out by contacting us.

Third-party marketing

We will get your explicit opt-in consent before we share your personal data with any company other than Acumen Insurance Services Ltd for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in set out in the table in paragraph 4 above.

External Third Parties as set out in the Glossary, which Acumen Insurance Services Ltd will be in a legal binding contract.
Third parties to whom we decide to go into business with, for example sell travel insurance on Acumen Insurance Services Ltd's behalf, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or
From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After your policy expires with us, we may keep your data for up to 7 years.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise these rights set out above, please contact us.

No fee usually required

You will not 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. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

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.