International Breakdown Ltd trading as National Breakdown and trading as Truck Assist
Last updated 21 May 2018
Purpose of this policy
- this website;
- the software applications made available by us for use on or through computers and mobile devices;
- our social media pages; and
- other social media content, tools and applications; and
- through other means (for example, from your application and claim and other forms, telephone calls, e-mails and other communications with us, as well as from vehicle recovery operators, claim investigators, witnesses or other third parties involved in our business dealings with you).
We process your personal information in accordance with the relevant data protection legislation. We are the data controller for the data that we process about you and we will not collect any information from you that we do not need for the purpose of administering your insurance policy or providing you with non-insured services (for example, our Pay As You Go service). There may be additional data controllers, such as the agent you purchased your insurance policy through, and the insurer who underwrites the policy.
Who to contact about your personal information
Why we collect your personal information
The provision of your personal information is necessary for us to administer your insurance policy and meet our contractual requirements under the policy and for us to provide other services to you, such as Pay As You Go assistance.
If you fail to provide the data, it may mean that you are unable to exercise your contractual rights, including claiming under the policy. This would also hinder our ability to administer your insurance policy or provide other services.
We also collect your information where we have specific consent from you to send you marketing information.
Personal Information that we collect from you and/or through our agent
Depending on your relationship with us (for example, as a consumer policyholder; non-policyholder; customer; insured or claimant; witness; commercial broker or appointed representative; agent; vehicle recovery operator or other person relating to our business), personal information collected about you may include:
- General identification and contact information
Your name; address; e-mail and telephone details; gender; date of birth; passwords on our systems; activity records, such as driving records; professional licenses and affiliations; relationship to the policyholder, insured or claimant.
- Identification numbers issued by government bodies or agencies
Driver’s or other license number.
- Financial information and account details
Payment card number; bank account number and account details.
- Medical condition and health status
Current or former physical or mental or medical condition; health status; injury or disability information.
- Other sensitive information
In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, or political opinions (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organisation). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us (for example, if you make us aware of a physical disability so we can better administer a claim or service provided to you).
- Telephone recordings
Recordings of telephone calls to our representatives and call centres.
- Information to investigate crime
Including data relating to fraud and money laundering. For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
- Information enabling us to provide products and services
Location and identification of property insured (for example, property address, vehicle license plate or identification number); travel arrangements including reservation numbers; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organisation; and other insurance you hold.
- Marketing preferences and customer feedback
You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.
- Social media account and information from Apps
We may receive certain personal information about you when you use our apps or social media content, including your social media account ID and profile picture, and other personal information that you provide to us. If you elect to connect your social media account provided by another social media service provider to your account(s) on any of our social media or other sites, personal information from your social media account will be shared with us, which may include personal information that is part of your social media account profile or your friends’ profiles.
Personal information collected from other sources
We may collect your personal data from others in the instance that you are a joint or additional insured party we may collect information about you from the policyholder.
We may also use fraud prevention sources, government agencies, or regulatory bodies (such as HM Treasury’s asset freezing list), or credit reference agencies.
How we use personal information
We use personal information to:
- Communicate with you and others as part of our business.
- Send you important information regarding changes to our policies, other terms and conditions, our web sites and other administrative information including renewal terms.
- Make decisions about whether to provide insurance; provide insurance and assistance services, including claim assessment, processing and settlement; and, where applicable, manage claim disputes.
- Assess your eligibility for Pay As You Go and insured services, and process your premium and other payments, including debt recovery.
- Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
- Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
- Carry out market research and analysis, including satisfaction surveys.
- Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.
- Personalise your experience on our web and social media sites by presenting information and advertisements tailored to you.
- Identify you to anyone to whom you send messages through our web sites.
- Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your personal information, so we suggest that you read these carefully.
- Facilitate social media sharing functionality.
- Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.
- Resolve complaints, and handle requests for data access or correction.
- Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
- Establish and defend legal rights; protect our operations or those of any of our companies or business partners, our rights, privacy, safety or property, and/or that of our companies, you or others; and pursue available remedies or limit our damages.
Sharing of personal information
We may make personal information available to:
- Our insurance and distribution parties
In the course of marketing and providing insurance and processing claims, we may make personal information available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; distributors; affinity marketing partners; and financial institutions and other business partners.
- Our service providers
External third-party service providers, such as vehicle recovery operators, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel assistance providers; call centre service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; third-party claim administrators; document and records management providers; claim investigators and adjusters; engineers; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
- Recipients of your social sharing activity
- Governmental authorities and third parties involved in court action
We may also share Personal Information with governmental or other public authorities (including, but not limited to, regulatory authorities, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property of us you or others; and (g) to allow us to pursue available remedies or limit our damages.
- Other third parties
We may share personal information with payees; emergency providers (fire, police and medical emergency services); retailers; medical networks, organisations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganisation, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, or assets. To check information provided, and to detect and prevent fraudulent claims, personal information may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to detect, prevent and investigate fraud. If you are benefitting from another party’s insurance policy or service arrangement with us (e.g. your employer), certain personal information relating to the administration of that insurance policy or service may be shared with that other party.
- Parties outside of the EEA
We will share data with parties outside of the EEA where this is necessary to carry out our obligations or offer service.
We use a number of parties to assist us in managing our business and some of these may at times hold or process data outside of the EEA such as Microsoft (email and cloud services), Amazon (cloud services) or Mail Chimp (marketing services). Where a company holds data outside of the EEA we check that they operate service, privacy and security standards equal to or greater than those required under EEA and UK rules.
We will take appropriate technical, physical, legal and organisational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any personal information you might have with us has been compromised), please immediately notify us. (See the “Who to contact about your personal information” section above.)
When we provide personal information to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the personal information
Retention of personal information
We will also retain data in an anonymous form for statistical and analytical purposes.
Following the end of the retention periods, your personal data will be securely destroyed.
Personal information of other individuals
We will provide you with opportunities to tell us your marketing preferences, including in our communications to you. We will only send you marketing information where you have expressly requested to receive it and only in the way(s) in which you have agreed (e.g. e-mail, letter, telephone, text message). You are able to change your preferences at any time. Please note; if you ask us to share your details with third parties for marketing and information purposes, you will have to contact the third party directly if you wish to change your communication preferences with them.
Access and correction requests and your rights as a data subject
You have the right to:
- withdraw consent where that is the legal basis of our processing
- access your personal data that we process
- rectify inaccuracies in personal data that we hold about you
- be forgotten, if the processing of your personal data is no longer necessary for the purposes it is collected for, your details would be removed from systems that we use to process your personal data
- restrict the processing in certain ways
- obtain a copy of your data in a commonly used electronic form (if the legal basis of our processing is consent or necessary for contract)
- object to certain processing of your personal data by us
Please see https://ico.org.uk for further information on the above rights. You may also contact us at firstname.lastname@example.org for further information. You have a right to complain to the Information Commissioner’s Office about the way in which we process your personal data. Please see https://ico.org.uk