1. Who we are and how to contact us
We are Healthinomad, the owner and operator of www.healthinomad.com. Healthinomad (referred to as “we”, “us” and “our” in this privacy policy) is the controller responsible for personal information processed by it.
It is important that you read this privacy policy carefully so that you are fully aware of how and why we use your personal information. We do not knowingly collect personal information relating to children under the age of 16 and children under the age of 16 should not use this website.
We have appointed a data protection officer (DPO) to oversee our data protection and privacy practices. If you have any questions about this privacy policy or if you wish to exercise your legal rights set out in this privacy policy, and then please contact our DPO using the details below.
Contact Details
Our contact details are:
Email: info@healthinomad.com
Our DPO’s contact details are:
Email: dpo@cogotec.com
2. Changes to this privacy policy
We reserve the right to amend or modify this privacy policy from time to time. All amended versions of this privacy policy will be posted on our website.
3. What types of personal information we collect
Depending upon the way in which you use our website and the individual products and services you are looking to buy, we may obtain the following:
a. personal information so that we can identify who you are. For example, this information may include your name and date and place of birth;
b. personal information so that we can contact you. For example, this information may include your home address, your email address and your contact telephone numbers;
c. personal information so that we can help you find a product or service. For example, this information may include details about you and your financial situation, your work or profession or the risk you are looking to insure;
d. other more sensitive personal information so that we can help you find a product or service. For example, this information may include details about your health or criminal convictions and offences. This data is known as “special category data” and we will only collect this data if the law allows us to do so; and
e. behavioural and/or technical personal information. For example, this information may include details about how you browse our website and the devices and technology you use to browse our website.
4. How we use personal information, the lawful grounds upon which we rely and why
How might you use my personal information? What lawful basis will you have to use my personal information in this way? Why do you use my personal information in this way?
We may share your personal information with our approved partners and third party product providers so that they can return a quote to you via email. This processing of your personal information is necessary so that we can provide our services to you in accordance with our website terms and conditions. If we process special category data for this purpose, we will do so only if the law allows us to and at all times strictly in accordance with the terms of our policy document. If you would like to view a copy of our policy document, click here. Without processing your personal information in this way we would be unable to provide our services to you.
We may share your personal information with a limited number of approved third party data providers in return for further information about you and/or the risk you are looking to insure. We use this further information for data enrichment purposes and in order to auto-populate relevant fields within our website journeys to save you time and effort. For example, if you run a car insurance quote and provide us with your vehicle registration number, we may search the databases of our approved third party data providers in order to auto-populate information about your vehicle (including, but without limitation, information about your vehicle’s make, model and estimated value). We have a legitimate interest in processing your personal information in this way. It is in our legitimate interests to process your personal information in this way so that we can provide a more user-friendly, intuitive and enjoyable price and product comparison experience. We know that our customers’ time is valuable and hence we strive to save people everywhere time and money!
We may process your personal information for the purposes of providing you with our continuous savings services, such as our “auto-quote” service. For example, if you have previously used our Health insurance comparison service then we may process your personal information in order to obtain a Health insurance quote on your behalf. We have a legitimate interest in processing your personal information for the purposes of providing you with our continuous savings services except where our provision of this service necessitates the processing of special category data. We will only process special category data for the purposes of providing our continuous savings services to you with your consent, if the law allows us to and at all times in accordance with the terms of our policy document. Our continuous savings services, such as our “auto-quotes” service, means that we do all of the hard work of generating a quote for you whenever your insurance policy or other product is due for renewal. We generate “auto-quotes” early which often means that we secure a better price for you via our website than you might obtain yourself by generating a quote on a date which is closer to your renewal date. You can still come back to our website and run your own quotes or simply confirm that the details we hold about you for the purposes of your “auto-quote” remain correct and then purchase your insurance policy or other product directly via your “auto-quote” – thereby saving you time and money!
If you opt-in to receive renewal reminders from us, we may process your personal information for the purposes of providing renewal reminders to you. For example, if you opt-in to receive renewal reminders from us and you have previously used our website to compare Health insurance, we may send you renewal reminders before health insurance is due for renewal. We will send your renewal reminder in advance of the date on which we understand your renewal is due. We will only process your personal information for the purposes of providing renewal reminders to you with your consent. Renewal reminders mean that you will be given plenty of notice to return to our website to make sure you are getting a great deal before your policy automatically renews or expires.
If you opt-in to receive general marketing from us, we may process your personal information for the purposes of providing our general marketing to you. For example, if you opt-in to receive our general marketing, we may send you newsletters, information about our latest offers, products and promotions and more. We will only process your personal information for the purposes of providing direct marketing to you with your consent. All of our marketing is carefully drafted and intended always to be topical, relevant and useful for our customers. Those opted-in are first in-the-know!
If you opt-in to receive contact from our partners who provide you with the two cheapest quotes, we may provide your contact details to those partners so that they can contact you in order to progress a sale. For example, if you opt-in to receive contact from our partners who provide you with the two cheapest quotes, one or both of those partners may contact you after you have run a quote via our website. Those partners may contact you for the purpose of assisting you in purchasing a product or service from them. Those partners should not contact you on more than three occasions within ninety days following the date on which you obtain a quote via our website. We will only share your personal information with our partners so that they can contact you in this way with your consent. We understand that some of our customers prefer to speak to an insurer before purchasing an insurance policy. By opting-in to receive contact from our partners who provide you with the two cheapest quotes, you may save a lengthy call queue and still purchase your preferred product in your preferred way!
We may process your personal information in order to send you service communications. This processing of your personal information is necessary so that we can provide our services to you in accordance with our website terms and conditions. Without processing your personal information in this way we would be unable to provide our services to you.
5. How we collect personal information
We collect personal information from you when you interact or engage with our website including when you register an account with us or compare products or services via our website. We may also collect personal information from you when you talk to us on the phone, by post or online including via email, social media and mobile device apps. We may also engage with you and hence collect personal information from you if you choose to provide feedback or take part in any of our other market research initiatives, customer surveys or competitions, prize draws or promotions. Occasionally, we may also collect personal information about you from third parties or publicly available sources, as set out in section 4 above.
6.Third parties with whom we may exchange personal information
We may share personal information with or receive personal information from:
a. other members of our corporate group;
b. our approved partners and third party product providers;
d. our regulators and other regulatory bodies, including the Financial Services Authority;
e. law enforcement and fraud prevention agencies; and
f. third parties to whom we may sell, transfer or merge parts of our business or assets or third parties whose business or assets we may acquire.
7.How our third parties may use personal information
We impose strict restrictions on the things that our approved partners and third party product providers may do with personal information that we give to them. Our approved partners and third party product providers may process personal information that we give to them in order to:
a. assess your eligibility for the products or services which you have expressed an interest in;
b. determine your identity and the amount of your premium and hence carry out checks:
i. with fraud prevention agencies in order to detect and prevent financial crime, including fraud;
ii. with credit reference agencies, which will appear as soft searches on your credit report and hence should not adversely affect your credit profile;
iii. with public and private higher education sources in order to verify your student or graduate status; and
iv. against information they already hold about you (for example, if you are an existing member of their loyalty schemes or otherwise already known to their corporate group); and
c. share personal information with their insurance underwriters, approved third parties (such as the DVLA if you give us your driving licence number) and relevant industry databases (such as the Claims and Underwriting Exchange which holds information about incidents reported to insurers that may or may not have resulted in a claim); and
d. conduct internal research (such as by analysing market trends and customer demographics) in order to develop the products and services which they offer.
If you intend to purchase products or services from any of our approved partners or third party product providers, you are strongly encouraged to read the terms of that partner’s or third party product provider’s own privacy policy in order satisfy yourself as to the purposes for which your chosen supplier will use your personal information.
When you leave our website, you are also strongly encouraged to read the privacy policy of every website that you visit in order to satisfy yourself as to the purposes for which those third party website owners and operators will use any personal information you give to them.
8. What communications you may receive from us
The communications we send to our customers can be categorised broadly as “direct marketing communications” and “service communications”.
a. Direct marketing communications
We understand that some of our customers like to receive only certain types of direct marketing communications. For us, this means drawing a distinction between our renewal reminders and our general marketing which includes our newsletters and information about our latest offers, products and promotions.
Because we draw a distinction between renewal reminders and our general marketing, you can choose to receive renewal reminders but not our general marketing and vice versa. Similarly, if you tell us that you do not want to receive renewal reminders or general marketing from us, we will not send any direct marketing communications to you.
b. Service communications
Service communications broadly comprise of communications which:
i. we have a legal or regulatory obligation to send to you (such as communications which we are obliged by our regulator to send to you from time to time);
ii. we send in connection with the provision of our services to you (such as our “best price” email, which we send to you immediately following your use of our service in order to confirm the best price for a product or service which you have compared via our website); and
iii. we send so that we can provide services at your request (such as password reset emails, which you may ask us to send if you do not remember your login credentials but want to access our products and services).
9. Sending personal information outside the European Economic Area (EEA)
We will only ever send personal information to providers outside the EEA if those providers are required to protect personal information in exactly the same way they would be required to protect personal information if they were based within the EEA. This means that we will only send personal information to a non-EEA country if:
a. the European Commission has determined that the relevant non-EEA country affords an adequate level of protection for personal information;
b. pursuant to agreement between us and the relevant provider based in the non-EEA country which contains data protection clauses adopted or approved by the European Commission; or
c. we send data to the US pursuant to the Privacy Shield.
10. How long we retain personal information
We may keep your personal information for up to six (6) years following the date on which you last use our website or only for as long as is reasonably necessary thereafter in order to:
a. respond fully to any questions or complaints;
b. evidence that we have treated customers fairly or satisfy some other legal, accounting, tax or reporting requirement; and
c. establish, exercise or defend legal claims in accordance with statutory limitation periods.
11. Data security
The security of personal information is extremely important to us and hence we have put in place appropriate security measures to protect personal information from being accidentally lost, used or accessed in an unauthorised way.
12. Your legal rights
a. Right of access
You have a right to know whether we are processing your personal information. If we are processing your personal information, you also have a right to request copies of your personal information that we are processing and certain further information, including the purposes of our processing and the recipients or categories of recipients to whom we have disclosed (or will disclose) your personal information.
b. Right to rectification
You have the right to require us to rectify or complete any inaccurate or incomplete personal information that we are holding about you.
c. Right to erasure
You have a right to ask us to erase your personal information. This is also known as the “right to be forgotten”. We must erase your personal information following your request except in limited circumstances prescribed by law, such as where we need to retain your personal information in order to comply with a legal obligation or in order to establish, exercise or defend legal claims. In these circumstances, we will restrict our processing of your personal information by putting it “beyond use”. This means that your personal information is deleted from our website and retained only in a separate and restricted database, where it will not be processed for any purpose other than as detailed above. Access to this database is managed by our DPO and is strictly limited.
d. Right to restriction of processing
You have a right to require us to restrict processing of your personal information where:-
i. you believe that the personal information we hold about you is inaccurate, and we require reasonable time to verify the accuracy of that personal information;
ii. your personal information has been unlawfully processed by us, but you do not want us to erase that personal information;
iii. it is no longer necessary for us to keep your personal information for the purposes for which they were collected by us but they are required by you for the establishment, exercise or defence of legal claims; or
iv. you exercise your right to object to processing and we require reasonable time to verify whether there are any overriding grounds upon which we may rely in order to continue that processing.
e. Right to data portability
If we process your personal information with your consent or because it is necessary for us to do so in order to provide our service to you, you may require us to move, copy or transfer that personal information to you or another third party in a structured, commonly used and machine-readable format.
f. Right to object
You have a right to object to our processing of your personal information where we are processing that personal information on legitimate interest grounds. We will stop processing this personal information if you exercise your right to object unless there are overriding grounds upon which we may rely in order to continue that processing or unless that processing is necessary in order to establish, exercise or defend legal claims.
You also have a right to object to our processing of your personal information for direct marketing purposes. You can object to our processing of your personal information for direct marketing purposes by unsubscribing via the unsubscribe hyperlink in any direct marketing messages which we may send to you. We will stop processing your personal information for direct marketing purposes if you request us to do so.
g. Right to withdraw consent
If we process your personal information with your consent, you have a right to withdraw your consent at any time. If you withdraw your consent, we may be unable to continue to provide certain services to you but we will inform you if that is the case.
13. Cookies
For information on the cookies we use, please click here.
14. Complaints
You can complain to us at any time and we appreciate the chance to deal with your concerns so please do contact us in the first instance.