Privacy & Cookie Policy

Who we are

• Wapp travel insurance is arranged by Wapp Limited which is registered in Gibraltar company number 111526. Registered office: First Floor, Grand Ocean Plaza, Ocean Village, Gibraltar.
• Wapp Limited is authorised and regulated by the Gibraltar Financial Services Commission and trades into the United Kingdom on a freedom of services basis. Financial Conduct Authority FRN 974092.

Policy Administration

• Policies are administered by Howserv Limited in the United Kingdom.
• Howserv is our outsourced service provider, which is registered in England and Wales, Company number 03882026.
• Howserv Limited is authorised and regulated for the administration of insurance policies by the Financial Conduct Authority, FRN 599282. The registered address of Howserv Limited is Britannia House, 3-5 Rushmills Business Park, Bedford Road, Northampton, NN4 7YB.

About Privacy Policy

• We are committed to data protection and data privacy. This policy describes how we (Wapp Limited) take care of your data when you use our website, web app, mobile app (iOS or Android) or purchase travel insurance from us.
• If you’ve got any questions about your data or what we do with it, you can get in touch with our Data Protection Officer at [email protected]
• By doing any of the below, you accept and agree to us using your data as described in this Privacy Policy:
• Buying insurance from us.
• Giving us your email address.
• Speaking with our customer services team.
• Downloading and using our mobile app.
• Accessing our web app.
• The Gibraltar Regulatory Authority are the supervisory authority for Wapp’s activities and this policy is governed in line with the Gibraltar Regulatory Authority guidance.

Your Data

Data we collect and how it’s collected

• Personal information; that is provided when you visit our websites or mobile apps or interact with the support team this includes your name, age, email address and other details you give to us.
• Location information; if you’re using our location based app, we will collect information about where you are. This is in order to provide the service(s) you’ve bought from us. Location-related information will be based on precise device location (if you’ve enabled the location services for the app), and IP address.
• Device information; we will collect device IDs from any mobile device(s) you have installed our ‘location based’ app on. This is in order to provide the service(s) you’ve bought from us.
• Insurance policy details; when you buy a policy from us, we retain a copy in line with regulatory requirements and to prevent/detect fraud.
• Website and Web App Usage; including visits to our websites, logging into the Wapp web app and information collected through cookies and other tracking technologies. This includes your domain name, browser version, operating systems, traffic data, location data, weblogs and other communication data. As well as any other data that you access from our website.
• Claims information; detailed data about your trip and the conditions of your claim. This may include medical data, such as an injury or illness, when submitting a claim.

Financial Information

• We don’t store any of your financial information such as credit card details.
• These are securely handled, directly and independently by our payment gateway provider, in line with Payment Card Industry Data Security Standards (PCI DSS).

What We Use Your Data For

• As the data controller, we collect and process information about you when you complete a quote through our app or on our website, telephone our contact centre or update your records via our app, so that we can provide you with the products and services you have requested. This will be your name, age, address, health information, travel dates, destination, and other information which is necessary for us to:
• meet our contractual obligations to you
• issue and administer this insurance policy including payments and other transactions
• service your policy
• detect, investigate and prevent activities which may be illegal, or could result in your policy being cancelled, or voided

Legal Basis

• The above data is processed for the ‘Performance of Contract’, or ‘Legitimate Interest’.
• The medical and/or health information you give us is processed as special category data, unless you’ve given your explicit consent or where the processing is necessary for reasons of public interest, i.e. in areas of great medical need.

Special Categories for Data

• Some of the more ‘sensitive in nature’ data is treated as a Special Category of personal data.
• This could be information relating to your health or criminal convictions.
• The collection of this information is conditional for us to be able to provide insurance or manage a claim. We’ll only use it for the purposes set out in this policy.
• If you’re giving us another person’s personal information, you should ask them to read our Privacy Policy.
• By giving us information about another person, you’re confirming that they have given you consent to give us their information.

Marketing

We may use your information to:

• Keep you up-to-date with relevant information by post, email or other means,
• About:
• Important notifications.
• Offers & customer rewards.
• Suitable products & services.
• We may carry out market research or data analysis to help us improve the services we provide or to design new services for the future.
• You have the right to request that we stop processing your personal information for marketing purposes at any time, you can do this by:
• Emailing us at [email protected]
• Writing to Wapp Customer Services at Howserv Limited, Britannia House, 3-5 Rushmills Business Park, Bedford Road, Northampton, Northamptonshire, United Kingdom, NN4 7YB.
• Please be aware that because we prepare some campaigns well in advance, whilst we will deal with your request straight away, it can take up to three months to stop selected marketing communications being sent to you.
• We may also collect information when you:
• Voluntarily complete customer surveys.
• Provide feedback and participate in competitions.

How Data is stored

• We securely store your information on servers located either in the United Kingdom or European Union.
• We keep and process this information to:
• Meet our contractual and regulatory obligations.
• Deal with requests from other authorities.
• You have the right to request a copy of the information that we hold about you and correct the information that we hold about you.

If you would like a copy of the information we hold about you please contact us by:

Emailing our Data Protection Officer at [email protected]

Writing to Data Protection Officer, Wapp, Britannia House, 3-5 Rushmills Business Park, Bedford Road, Northampton, NN4 7YB.

How long Data is Stored For

• We will only retain your data for as long as we require it.
• It will be stored for no longer than 7 years after your policy ends.

Links to other third-party websites

• Other websites will have their own privacy policies.
• If you click on a link that takes you to another website, we won’t accept any responsibility for what they do with the data you give them.

Sharing Your Data

We may process your personal information for our legitimate business interests. ‘Legitimate Interests’ means the interests of Wapp in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience.

It can and does also apply to processing which is in your interests too. Processing for our legitimate interests may include processing for the purposes of:

Fraud prevention and compliance.

Certain direct marketing and promotional activities.

The provision and operation of referral marketing programmes.

Network and information systems security.

Data analytics.

Enhancing, modifying or improving our service.

Identifying usage trends; or determining the effectiveness of promotional campaigns or advertising.

In connection with the above activities, we may share your personal information with trusted suppliers who assist us in our data processing activities.

When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).

You have the right to object to this processing if you wish and if you wish to do so please contact us by;

• Emailing our Data Protection Officer at [email protected]wapp.com.
• Writing to Data Protection Officer, WAPP, Britannia House, 3-5 Rushmills Business Park, Bedford Road, Northampton, NN4 7YB.

We will only share your information with:

Howserv, so they can administer your policy.

The appropriate Underwriter (dependent on the product purchased) so that, if you ever need to make a claim, it can be dealt with.

Mention-Me Ltd for the purposes of operating our refer a friend programme.

We won’t share your information with anyone else unless we are required by our regulators, or other authorities.

We won’t pass your personal data to any party outside of The Staysure Group for the purposes of marketing products or services to you.

Cookie Policy

When you visit a website it is likely to place one or more ‘cookies’ in your web browser’s history files. A cookie is a small file that acts as the website’s memory about your visit. Cookies are used to make websites work efficiently and provide information to the owners of the website.

Some websites, including ours, also set ‘third-party’ cookies – these are cookies created by other companies that we use to help us deliver a better service. It is possible to configure browsers to block cookies but this may make some websites difficult or impossible to use. Some browsers allow you to choose to block first-party, third-party, other sets of cookies or individual cookies, so that you can decide what to allow on your device.

What are cookies?

Cookies are small text files which are stored on your device when you visit certain web pages. Cookies identify your device and enable information about the use of your computer to be stored on its hard drive. This information is then used for many things like remembering whether you’ve visited the site before or to help us work out how many new website visitors we get each month.

It is important to note that cookies can’t harm your computer. We use encrypted information gathered from cookies to help improve our customer’s experience on the site by, for example, helping us to identify and resolve errors.

How we use cookies and other tracked data

• to ensure the security of your e-commerce transactions via our website
• to create a ‘shopping basket’ during your visit
• to discover which technologies your browser supports so that we can deliver the best user experience possible
• to tell us how our website is found – this helps us determine the effectiveness of our online marketing channels and reward some external websites for referrals
• to measure what happens during your visit so that we can determine the effectiveness of our pages and test different versions (this information is not associated with your personal data, it is anonymous)
• to record shares of our pages on social media
• to advertise to you on other websites
• to help us deliver our webchat service so that our specialists can help you during your visit
• to better understand you and your interests so we can create a more relevant browsing experience
• to measure the visibility of our online ads and their impact on our website performance

Our cookies don’t store any sensitive and /or personal information such as your name, address or credit/debit card details. They are used to ensure that when you return to our site your experience is more personalised.

If you would like to restrict, block or delete cookies from any website, you can use your web browser to do this. Check the ‘Help’ menu of your particular browser to learn how to change your cookie preferences.

Google Analytics Advertising Features we use on our site

One of the tools we use on our website and in our apps is Google Analytics. This is a web analytics service that helps us understand how you use our website and what improvements to make. Google Analytics also helps us to target our advertising. Some of the features we use include:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• Google Analytics Demographics and Interest Reporting
• Integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers

You can change how Google’s systems use cookies and data Google gather here – https://myaccount.google.com/privacy#ads

Third party cookies

If you ‘share’ content from our website with your friends on social media networks – such as Facebook – you may be sent cookies from these websites. We don’t control the settings of cookies on these third-party websites, however they should have more information about their cookies and how to manage them available on their websites.

Please note that we’re not responsible for the content of external websites.

Mention Me are a 3rd party service provider who will place functional cookies if you interact with our refer-a-friend programme’.

Here is a link for you to be able to see what those cookies are and why they are used.

https://mention-me.com/help/privacy_policy_s#cookies

Opt out of cookies

You can set your internet browser not to accept cookies and remove them from your browser. For further information visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of receiving communications through the following platforms, follow these “opt out” processes:

Google – https://myaccount.google.com/privacy#ads

Bing – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Facebook – https://en-gb.facebook.com/help/146952742043748

Twitter – https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads

VE Interactive – https://www.ve.com/privacy-policy

AdRoll – http://www.youronlinechoices.com/uk/your-ad-choices

Email – you can unsubscribe at the bottom of any email you have received from us.

Others not named above (remove specific advertising cookies) – http://www.youronlinechoices.com/uk/your-ad-choices

Please refer to the Network Advertising Initiative website for more information.

Your Rights

• Under the Data Protection Act 2018, you have the following rights:
  • To obtain a copy of your data that we hold, via a Data Subject Access Request.
  • To have the data corrected if it is inaccurate or incomplete.
  • To have the data deleted, although this may not always be possible, if we still need to process it, i.e. for a claim or complaint.
  • To ask us to stop processing your data in certain circumstances.
  • To receive a copy of your personal information in a durable format which can be shared by you.

Updating this policy

• We may update this policy at any time by uploading the new policy to our website and app.
• The updated policy will be effective from the date it’s posted.
• We will always aim to let you know of any important changes to this policy.
• If you don’t agree with any changes we make to this privacy policy, you can let us know and we can close your WAPP Doing this will cancel any active policy you have with us.