TripDoctor Privacy Policy

Overview:

This privacy policy sets the terms of how TripDoctor Insurance LLC (“TripDoctor”), its affiliates, subsidiaries and / or parent companies will collect, utilize and protect personal information and information rights. TripDoctor is dedicated to ensuring the highest standards of care in protecting its applicant’s and customer’s privacy and any use of personal information.

TripDoctor’s Role in the Control of Personal Information:

TripDoctor is an Information Controller, an organization that collects and holds personal information. As an Information Controller, TripDoctor may process personal information through its request, information collection, storage, retention, analytics, sharing, and removal. When applying to or purchasing TripDoctor for insurance coverage, TripDoctor will serve as an information controller of the applicant’s or customer’s personal information as well of that of any family member(s) included on an application or issued policy. TripDoctor is registered with all relevant Supervisory Authorities required by law for these purposes.

Why Does TripDoctor Require Personal Information?

TripDoctor needs to acquire personal information to provide applicants and customers with insurance quotes, underwriting, service, questions, and to assess whether the products or services it offers can meet an applicant’s needs. In particular, prior to entering into an insurance contract with an applicant, TripDoctor’s or one of its affiliates’ underwriting team will require personal information prior to policy issuance. In some cases, TripDoctor may already hold certain personal information of an applicant or customer. If, for example, an applicant currently has or previously had a policy with TripDoctor, TripDoctor may use this personal information to avoid collecting it again.

What Personal Information Does TripDoctor Collect?

TripDoctor collects, stores, and uses a range of personal information in order to serve its customers and operate its business. Listed below are a non-exhaustive list of personal information types TripDoctor may ask applicants or customers for when they look for either a quotation or policy.

What Types of Personal Information Types TripDoctor Collect?

Name, gender, age, date of birth, citizenship, nationality, passport, other government identification, driving license, national identifier number(s), visa information, occupation, employment status, family details (such as marital or domestic partner status, dependents, next of kin), permanent address, mailing address, future address, email address(es), phone number(s), call records and recordings, smartphone application data, geo location data, direct marketing preferences, and others.

Why Does TripDoctor Need Personal Information?

At times, TripDoctor may request personal information that might seem sensitive. In particular, some of TripDoctor’s products require medical underwriting following the application process. This requires questions about the applicant’s and / or the applicant’s family’s health or medical history that could impact insurance coverage or premium rates. This is known as ‘special category information’. In general, TripDoctor does not collect special category information, but sometimes the personal information collected may reveal it. This will be, limited to the minimum required for business purposes. As an insurance producer, TripDoctor may need to collect this information to make regulatory or internal filings and reports, such as: health, medical conditions, injuries, sicknesses, and more.

Where Does TripDoctor Obtain Personal Information From?

TripDoctor collects personal information directly from its users and customers when they create an account on its websites, apply for its products or services in person, by phone, by videocall or online. To ensure the accurate recording of personal information, TripDoctor may, at its discretion, record written correspondence (physical or electronic), electronic chats or voice / video calls with its users, applicants and customers. TripDoctor may also acquire personal information from public sources where the owner of this information has made it public, such as on the owner’s social media profiles. TripDoctor also may obtain personal information relating to applicants or customers from third parties during the application and underwriting process for one of its services or products.

How Does TripDoctor Handle the Personal Information of Minors?

While TripDoctor does not sell products directly to minors, it may need to capture such information from the minor’s parent or legal guardian when they source or apply for a family insurance policy. In the interest of minimizing the risk to minors, TripDoctor only collects the minimum necessary personal information on minors needed to provide an insurance quote or submit an insurance application for underwriting purposes. The personal information of minors is protected to the same high standards as all personal information the company collects.

When Does TripDoctor Use Personal Information?

TripDoctor uses personal information for various purposes. TripDoctor collects, uses, shares or holds personal information only for valid reasons referred to as a “Lawful Basis”. Lawful Basis include:

With Consent: The personal information owner has provided clear consent, free of duress, for TripDoctor to process their and / or their family’s personal information for a specific purpose.

With Explicit Consent: The personal information owner has given explicit consent for TripDoctor to process their and / or their family’s personal information for a specific purpose.

To Contract: The personal information is necessary to obtain a quote, process an application or establish a contract with the owner and / or immediate family member of the personal information.

For Legal Obligation: TripDoctor must use the personal information to comply with laws, regulations or legal requirements.

For Legitimate Interest: The personal information is required for the legitimate interests of TripDoctor or a third party, unless there is sufficient reason to protect the personal information which overrides these legitimate interests.

How Does TripDoctor Use Personal Information?

TripDoctor uses personal information for a various purpose. When TripDoctor collects, uses, shares or holds personal information, it only does so with a valid reason or Lawful Basis listed above. It does this for the purposes of communication with applicants or customers via multiple communication channels, including in-person, online, chat, phone or video calls, among others.

Change in Purpose

TripDoctor strives to only use personal information for the purposes for which it was collected. Exceptions can occur if TripDoctor reasonably considers that it needs to use collected personal information for an additional reason to the reason for which it was originally collected, and the new reason is compatible with the original reason. Whenever this situation arises, TripDoctor strives to communicate with its applicants and customers to explain the legal basis which compels it to do so.

Transfers of Personal Information Across International Boundaries

As the nature of TripDoctor’s business is to provide insurance that covers its insureds across borders, TripDoctor will, from time to time, need to transfer personal information across international boundaries. While TripDoctor’s main offices are located in Madison, Wisconsin and San Juan, Puerto Rico, USA, it may from time to time, need to collaborate with contractors and third parties outside of the USA. This may be required in the day-to-day course of business or to service a customer located outside of the USA. TripDoctor will only transmit personal data across international boundaries when required or permitted to by necessary business activities, law or regulatory requirements.

Securing Personal Information

TripDoctor enacts through and appropriate security measures to protect personal information. These include industry standards to prevent the loss, use or theft of personal information. TripDoctor limits access to personal information to only those who have a business need to use it. TripDoctor employees and representatives using personal information do so in a secure environment and in an internally authorized manner. All such employees and representatives are trained and adhere to a duty of confidentiality. TripDoctor keeps strict procedures to deal with known or suspected breaches of personal information. If and when such breach is confirmed, TripDoctor will notify affected parties and the applicable regulator(s) as legally required.

Personal Information in the Case of a Sale of All or Part of TripDoctor’s Business

In the event of a pending or completed sale of all or part of TripDoctor’s business, TripDoctor may transfer or share customer data or information as part of the pending or completed sale. In this event, TripDoctor will ensure adequate personal information protection through contractual obligations with the buyer to ensure the protection, confidentiality and security of personal information.

How Long Does TripDoctor Retain Personal Information?

With some exceptions, TripDoctor reserves all personal information for up to 7 years following the last interaction that the personal information owner had with TripDoctor. In the case of direct marketing preferences, TripDoctor will retain this information until such time as the owner communicates that they no longer wish to receive direct marketing messages. At the written request of the owner of personal information, TripDoctor will securely dispose of said personal information as requested.

Obligations to Ensure the Accuracy of Personal Information

TripDoctor makes all reasonable efforts to ensure personal information it holds is correct. In the event that the owner of personal information becomes aware of inaccuracies in the personal information TripDoctor holds, TripDoctor requests that the owner contacts the company to report any inaccurate or incorrect personal information once identified. If the owner is an insurance customer, it is the owner’s responsibility to inform TripDoctor of any change in personal information, including but not limited to changes in name, address, phone number, email, family member personal information, etc.

Contacting TripDoctor About Personal Information Issues

When the owner of personal information has concerns or issues regarding how TripDoctor collects, stores, uses , analyses, shares or maintains personal information, or if there is a suspected breach in such information, please immediately contact TripDoctor at info@tripdoctor.com to communicate these concerns.