Last update: December 2018
Your personal information
3. What is personal, sensitive and health information?
4. How we collect your personal information
5. How we collect your sensitive and health information
6. Use, transfer, handling and sharing of your personal information
7. Transferring personal information overseas
8. How accurate is your personal information
9. Protecting your personal information
10. Marketing our products and services
11. When we share your information with other parties
Your privacy on the internet
12. Collection of other information
Dealing with Cover-More
13. Resolving your privacy issues
14. Gaining access to and correcting your personal information
15. Dealing with us anonymously or under pseudonym
16. Your travel consultant and your personal information
17. Contact us
Cover-More is committed to the safe and careful use of your personal information. We take reasonable steps to protect any personal or sensitive information you provide to us from misuse, interference, loss, unauthorised access, modification or disclosure. We will always be open and transparent with you about how we handle information.
Cover-More Group Limited is a travel insurance, medical assistance and data analytics group of companies.
|Company Name||Australia Business Number (ABN)|
|Cover-More Insurance Services Pty Ltd||95 003 114 145|
|FitSense Insurance Services Pty Ltd||41 622 132 530|
|Travel Insurance Partners Pty Ltd||73 144 049 230|
|World Travel Protection||80 079 071 579|
Australian members of our Group are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
For more information about the Group, including a complete list of our Group entities, see http://www.covermoregroup.com.
This Policy will be reviewed at least annually to ensure it remains up to date. It was first prepared in February 2014 and may be amended from time to time by posting the amended version on our website.
For further information on privacy in Australia, please visit the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.
Personal information is information that can identify or reasonably identify you.
We will only collect personal information to assist or enable us to perform one or more of our functions or activities. We collect the personal information we need to provide travel insurance and travel related products and services, including assistance when you are travelling.
The type of information Cover-More collects and holds varies depending on the type of product or service we provide to you. For example, Cover-More will hold different information about you if you have a travel insurance policy than if you make a claim on a policy or require assistance when travelling. This information may include information about a permanent or temporary medical condition that you have or health information in general.
Cover-More regularly collects, holds, uses and discloses health information and is committed to protecting the privacy of this type of information to a higher degree than that of other personal information.
Cover-More may collect and hold the following personal information (including sensitive and health information) regarding:
Cover-More collects personal information from and on behalf of customers, business partners, suppliers, employers (relating to corporate policies), other insurers and third-party service providers.
We will, if it is reasonable or practicable to do so, collect your personal information directly from you. This may happen when you fill out an application form for travel insurance, become one of our representatives, create an account to use our iPhone and Android mobile application software (“Apps”), make a claim or request assistance. This may occur over the phone, via email, an App, a website or through one of our agents or partners.
In certain cases, we collect your personal information from third parties. For example, we may need to collect personal information from your representative (such as a legal guardian), your travel consultant, the primary policy holder or any of the other organisations.
We will collect your personal information from Health Trackers where you have authorised us to do so. If you are an authorised representative or third-party service provider we may obtain information from a credit reporting agency or your agency group head office.
If your company is the applicant on a corporate policy, we may receive your details from your employer.
In addition, we collect information when you visit our website, Facebook page and other pages that we own and manage.
We may also collect information by other means and will take reasonable steps to inform you if and when we do if not already explained in this Policy.
Your health information, such as pre-existing medical conditions, is generally required to arrange travel insurance and travel related products and services, to make a determination on a claim or to provide you with medical assistance.
If you provide health information to your agent or consultant to provide to us as part of the policy application or claims process, we rely on you having provided them with your consent to disclose this information to us. In addition, when you provide information, including sensitive information about other individuals on your travel insurance policy, we rely on you to inform them of the information you are providing, how we will use, hold, collect and disclose this information and on you obtaining their consent.
We may collect your health information from Health Trackers. We will only do this if you have given your consent.
If we do not have your consent, we will not collect your sensitive personal information. This is subject to some exceptions including where the collection, use and disclosure of the information:
We use your personal information to provide you with the relevant products or services you have requested including:
When handling claims Cover-More only uses the personal information which is relevant to making a decision about the claim.
We may also use the information (which is not sensitive information) to send you material about Cover-More’s other products or services or products and our business partners’ services as described in Section 10 (Marketing our products and services). We will only use your sensitive information for this purpose if you have consented to that use.
We may also use or disclose your personal information for another purpose for which you may reasonably expect it to be used or disclosed by us and that secondary purpose is related or (if sensitive information) directly related to the purpose for which it was collected.
Otherwise we will only use your information for a secondary purpose if you have consented to this use or disclosure, the use of disclosure is required by law or an enforcement body, to take appropriate action in relation to suspected unlawful activity or serious misconduct or to provide assistance in a medical emergency.
We use and in some instances, disclose your personal information when we, or third parties appointed by us, provide the following services:
To provide you with mobile tracking services, our Apps require us to determine your location which is collected through your IP address whenever you interact with, or use our services eg open an App, visit our website etc. We collect information to locate you from a number of sources, including;
This information is only collected if you have location services turned on. If you use an App and have enabled background location services in our Apps, you consent to us and our affiliates’ and licensees’ transmission, collection, retention, maintenance, processing and use of your location data to provide and improve location-based products and services, even when you do not have the App open (as permitted by your device settings). If you have background location data turned on, you may withdraw this consent at any time by turning off the location services settings on your device.
You acknowledge that if you choose to turn off location services, the functionality of an App will be limited. In particular, we will not be able to track your exact location in real time and may not be able to provide with active management support in the event that an incident takes place whilst you are travelling and you require assistance. We will also be unable to send you real-time alerts relating to your travel location.
To provide you with a more personal experience, such as providing you with products and services that are relevant to you, we may use and disclose your personal information for the purposes of providing, administering, improving and personalising products and services for you. In order to do this, we may exchange, share and combine personal information (other than sensitive information; if we do share sensitive information we will get your express consent) that we have collected from you (or disclosed to us). We may share your information with related entities of Cover-More, our business partners and service providers to assist with services such as data processing and matching, data analysis, data monetisation services, information broking, business consulting, marketing and research (“analysis services”).
We may use such analysis services to also help us improve our products and services, the way we sell our products and services to you and to help us improve customer experience by understanding purchasing trends, your interests, relevancy of products and services and how you would respond in relation to products, services and offers from us or third-party providers.
The business partners and service providers we use to provide us with analysis services will generally be located in Australia but may be located in other countries from time to time. Before disclosing, exchanging or sharing such information, we take steps to ensure that our business partners and service providers are obliged to protect the privacy and security of your personal information and use it only for the purpose for which it is disclosed.
When we are provided with the results of such analysis services, we, our business partners or service providers may provide marketing communications and targeted advertising to you on an ongoing basis by telephone, electronic messages (e.g. email), digital services (e.g. through Apps) and other means. These communications may relate to the products and services we or our group of companies offer, our business partners offer, or other products and services which may be of interest and relevant to you.
At any time, you can advise us that you wish to opt out of future contact by contacting us via our customer service team on 1300 72 88 22 or via the unsubscribe function in all our email, or text marketing communications, or in the App settings on your device.
By purchasing a policy through us, you are consenting to us sending your information to overseas parties if required to provide you with medical and non-medical assistance or to progress and assess your claim.
The countries we typically disclose your personal information to under these circumstances are generally located in the geographic regions you travelled during the duration of your policy.
We may also need to disclose information to service providers who are located overseas who assist us by managing and authenticating some customer data or by seeking feedback from our customers to help us improve our products and services. Who those service providers are and where they are located may change from time to time. You can contact us for details.
While we are committed to protecting your information from misuse, loss or interference when your personal information is sent to third parties overseas, in some cases we may not be able to take reasonable steps to ensure that those third parties do not breach Australian privacy laws and the information may not be subject to the same level of protection as is provided for under Australian privacy laws. You may not be able to seek redress under Australian privacy laws or under laws in the overseas jurisdiction in the event of any misuse, loss or interference with your personal information.
The nature of our business means it is often necessary for us to send your personal information outside Australia. This occurs because our business and the third parties have operations in countries across the world. For example, where you are flying outside of Australia, and you require assistance, your personal information will be transferred to the medical provider responsible for your care.
When assessing your claim, we may refer to information provided by our third party medical and non-medical assistance providers, who include related entities.
We may also use related entities to process and assess your travel insurance application or claim and to administer your insurance policy. These related entities may be based in Australia or overseas in: New Zealand, United Kingdom, Malaysia, China or India.
Some business departments within the Cover-More Group may enter into outsourcing arrangements to countries other than those listed above.
In addition, we may transfer your data to parties in countries outside the country in which you are located to provide services to us.
This may involve sending your data to countries where under their local laws you may have fewer legal rights. If you are located in the European Economic Area (“EEA”), you have certain rights under European law with respect to your personal data, including the right to request access to, correct, amend, delete, transfer to another service provider, or object to certain uses of your personal data. If you wish to exercise these rights, please contact us as detailed in Contact Us section.
Cover-More takes reasonable steps to ensure that the personal information collected, used or disclosed is accurate, relevant, complete and up-to-date.
If you believe your personal information is not accurate, complete or up to date, please contact the Cover-More’s customer service team on 1300 72 88 22.
We take reasonable steps to securely store your personal information so that it is protected from unauthorised use, access, modification or disclosure. We store personal information in different ways, including in paper and electronic form, on both Cover-More premises and its data centres and our service providers premises and data centres, which include IT service providers and document storage and management providers.
We maintain administrative, technical, and physical safeguards for the protection of personal information. Our security measures include, but are not limited to:
While Cover-More has security measures in place to protect your data, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Cover-More cannot warrant or ensure the security of any information you transmit to us or we transmit on your behalf, or to you, in the course of providing services over the internet, or through our Apps.
We may from time to time, provide you with information about other products, services and offers.
If you do not wish to receive this information, or wish to know the source of the information, please contact the Cover-More customer service team on 1300 72 88 22. You can change your mind about receiving information about our products and services at any time, by contacting us or using the opt-out process on our offers or promotional communication.
Please note we will still need to send you essential information about your insurance, travel alerts, policy and claim documentation and Global Sim registration information.
Before discussing the progress of a claim or the medical and non-medical assistance that we provide with third parties (other than the parties involved in providing such a service), for example, a relative or companion, we will obtain appropriate consent from you, your parent or guardian, power of attorney or executor (as relevant).
Below are the types of entities Cover-More may collect your personal information from and may disclose your personal information to. This is not an exhaustive list.
Cover-More may also collect non-personally identifiable information such as the type of browser, or operating system you use, your domain name, IP address, access times, referring website addresses and page views. Our Internet Service Provider (“ISP”) automatically identifies your computer by its IP address. When you visit pages on our website, our ISP may log your IP address. We do not link IP addresses to any personally identifiable information. Your IP address is used to gather broad demographic information only. A User Transaction ID is created each time you enter our website. This ID is used to keep track of your dealings with us, and other requests.
A cookie is a small, text-based file used frequently on some websites and portals. They are designed to assist and streamline the exchange of information between your computer's browser and our computer systems. Some cookies used by Cover-More collect information about the use of our websites. The information collected includes where visitors connect from, what version of browser they use and their path through the site. It helps us to provide personalised features and keep our content fresh and relevant.
If you are a current or former customer of Cover-More, we may use a special cookie that identifies you. We may use the cookie to collect the website and browser information referred to above and may combine that information with your customer history and other personal information we hold about you. We may use and disclose the combined information for performing the analysis services and sending you marketing communications and targeted advertising as described in this Policy, as well as using and disclosing it for the other purposes described in this Policy.
Our web pages may contain electronic images, known as web beacons or spotlight tags. These enable us to count users who have visited certain pages of our website. Web beacons and spotlight tags are not used by us to access your Personal Information, they are simply a tool we use to analyse which web pages customers view, in an aggregate number.
Links to other websites
Our web sites may contain links to non-Group web sites. Whilst such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours.
You can request access to your personal information in most cases without restriction or charge. If charges are applicable for providing access we will disclose these charges to you prior to providing you with the information. In limited circumstances, a request for access may be denied, or restricted access given. We will provide reasons in writing for the denial of or limitation on access.
To arrange access please contact us (see the Contact Us section). In some cases, we may be able to deal with your request over the telephone. Access to the requested information may include providing you with copies of the original documentation, providing you with the opportunity for inspection of the documentation at our premises or providing you with a summary.
We will correct personal information if we discover, or you are able to show that the information is incorrect. If you seek correction and Cover-More disagrees that the information is incorrect, we will provide you with our reasons for taking that view and advise you on the further steps you may take.
You can deal with us anonymously or you may use a pseudonym where it is lawful and practicable to do so. For example, you may inquire about our products or request a quote. However, we regret that we will not be able to offer you travel insurance, assess and pay your claim, appoint you as our authorised representative or provide you with medical and non-medical assistance if we cannot identify you.
We require our agents and partners to handle your personal information in a manner consistent with this policy. Your travel consultant is authorised to arrange your travel insurance.
We rely on you having provided your travel consultant with your consent if you would like us to share information about your claim or existing medical condition assessment with them. You may choose to deal directly with Cover-More if you prefer not to provide them with information about existing medical conditions and health related matters included in your claim.
Email: [email protected]
Phone: 1300 72 88 22
The Privacy Officer
Cover-More Insurance Services Pty Ltd
Private Bag 913, North Sydney, NSW 2059
Email: [email protected]