Privacy Statement

Travers & Co. Insurances Limited are committed to protecting and respecting your privacy.  We wish to be transparent on how we process your data and ensure you understand your rights.  This privacy statement explains to you what to expect when you supply your personal information to Travers & Co. Insurances Limited trading as Travers Financial Services, Travers Insurances. (“we”, “us”, “our”). Reference to “insurance company” hereafter means any of the following: insurance companies, managed general agents, underwriting agencies, insurers and product producers.

Collecting personal information about you for the purposes of engaging in intermediation activities relating to certain financial products and/or the provision of advice in relation to those products is necessary and legitimate.  We set out hereunder further explanations in Plain English so that you can become aware of all the different data processors and sub-processors who may obtain your information, and we also set out the reasons for this processing. This privacy statement is effective from 15th of May 2023.

We reserve the right to change and amend this privacy statement from time to time to take into consideration new technology, changes to our operations and practices and new laws and regulations.  Our most current privacy policy will govern any personal information we hold on you.

1. General

We are the data controller of your personal data.  Should you wish to contact us in relation to any aspect of our use of your personal data, please contact our Compliance Officer:

Phone:              0818 287 222 / 0402 32204
E-mail:              dataprotection@travers.ie

Address:           7 Upper Main Street, Arklow, Co. Wicklow. Y14 KT63

Our friendly staff will be happy to assist with any queries you may have.  

The services and intermediation activities we provide are advice and assistance in the placement and arrangement of general insurance, life, pension, savings and investment products suitable to your needs and this statement applies to information we collect about you:  

• Should you visit us in person at our main office, contact us by telephone or through our website the process is similar. Our website is a brochure website which allows you to submit your Name, Email Address, Phone Numbers, Type of Cover Sought, and Brief Description about your enquiry. This information is then sent to our qualified team of advisors who will assist you with your enquiry. Please note that we will need to collect further information that is necessary for the purposes of engaging in intermediation activities and/or the performance of your insurance contract and to fulfil the duty of care that we are required to provide to you.

• Should you choose to select a third party to supply your information to us, in the interests of good business practice we will facilitate this on the understanding that you have given your consent to the third party to supply this information to us on your behalf.

• All personal data we gather will be processed in accordance with all applicable data protection laws and principles, including the GDPR and the Data Protection Acts 1988 – 2018 and, any other law and regulatory requirements relating to the processing of personal data and to privacy, including Directive 2002/58/EC and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 and the Consumer Protection Code.

2. What Information do we Collect?

Your proposal form contains all types of legitimate questions that an insurance company can ask in respect of an insurance risk that you seek cover for, depending on the types of risks you wish to obtain a quotation for, we will need to ask you certain types of questions, they include but are not limited to:

• Full Name which may include middles name(s)
• Address & Eircode
• Place of Residence & Previous Residence (should it be necessary)
• Date of Birth (This may be linked to databases for fraud detection)
• Gender
• Telephone Numbers / Email Address
• Credit / Debit Card and Bank Account details
• Medical / Health / Health Related Information
• Unspent Criminal Convictions
• Marital Status
• Previous Claims History
• Employer Details
• Driver Licence Details
• Penalty Points / Road Traffic Offences
• Telematics Data
• GPS Tracker Information

We also provide a premium finance credit facility which may be of interest to you.  Should this be the case our partners may need to complete credit checks regarding your financial history and receive Proof of Identification in the form of a driving licence and/or passport, copy of recent Bank Statement and Proof of Address.  

Should it be the case that you wish to insure another person such as a named driver(s) under your motor insurance policy or a spouse living with you in the home under your house insurance policy or include another interested party on any other policy type, we may need similar information regarding these persons/parties.  Should you provide this information, we will assume that you have been given the consent of these persons/parties to supply this information to us. You should make these other persons/parties aware of this privacy statement, inform them that it also applies to them and give them our contact details outlined above should they wish to contact us with any concerns they may have.

3. Do you need to supply this Information to us?

We request this information from you for the purposes of engaging in intermediation activities relating to certain financial products and/or the provision of advice in relation to those products.  If we are collecting your data for this purpose and you cannot provide this data the consequences of this could mean the contract cannot be completed and/or details are incorrect and may result in a policy being cancelled, claims not being paid and your encountering difficulty in trying to purchase another insurance contract.

However, you do have a range of different options available to you in respect of the current data protection regulations and Acts, some of these include the Right to Restriction, Right to be Forgotten, Right to Data Portability and the Right to Object.  Should you require more information about your rights please visit www.dataprotection.ie.

4. Your Consent

Where the use of your personal information by us requires your consent, such consent will be provided to us in accordance with our terms of business available at www.travers.ie or any other contract we may have entered into with you or stipulated in our communication with you from time to time. Where we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw your consent at any time by contacting us.  

5. Why we need to collect Sensitive Information about you?

We will process your personal data where it is necessary for us to comply with our contractual obligations to you, or where we need to take pre-contractual steps at your request.

We will process your personal data where necessary for the purposes of our legitimate interests. “Legitimate interests” means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. For example, we may process your information to protect you against fraud when transacting on our website and to ensure that our websites and systems are secure. When we process your personal information for our legitimate interests, we make sure that we consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests –we will not use your personal data where our interests are overridden by the impact on you (unless we are required or permitted by law).

Your Insurance Company may process personal data they receive about you from third parties including but not limited to us, business partners, other insurers, claims teams and fraud prevention agencies.

Insurance is a risk-based market therefore insurers request your information so that they can evaluate and cost rate the risk accordingly, for the performance of your contract you need to disclose all material facts which are material to your insurance contract. 

Some of the material information and facts you may have to disclose are regarded as sensitive information such as Unspent Criminal Convictions data or Health data.  If there are questions related to unspent Criminal Convictions or Health on your proposal form, we will need to ask you about them.  

Data Concerning Health is personal data which is regarded as more sensitive and so needs greater protection, such as medical records. In the event that you disclose such information to us we will assist you with greater security needs.  In such circumstances, where necessary to protect your health, your insurer may process and share such data either with your explicit consent or, where this is not possible, they will do so in order to protect your vital interests.

6. Who gets to Access your Personal Data and Sharing your Information?

Assuming you purchase an insurance, life, pension, savings or investment product from us, during the life of your policy and for a legitimate time thereafter, a range of different third parties may obtain your data for any further processing, we may share your information with third parties which includes but is not limited to:  

• Insurers / Underwriters / Managing General Agents (MGA’s) / Sub-Brokers / Re-Insurers
• Vehicle Repair Companies / Property Repair Companies
• Motor Assessor(s)
• Loss Adjusters / Loss Assessors
• Solicitors / Accountants
• Witnesses to an accident
• Forensics Experts or Claims Investigators
• Law Enforcement agencies like the Gardaí
• Regulatory authorities like the Central Bank
• Credit Reference agencies
• Central Credit Register
• Company Director Search Websites
• Financial Services Ombudsman  
• Injuries Board
• Brokers Ireland / Insurance Ireland
• Decision Support Service including any appointed decision supporters

In accordance with their remit, insurers may seek highly confidential information about you from other sources, these include but are not limited to:

• Publicly available information including social media sites, online content, newspaper articles, TV, radio and other media content, court judgements.
• Insurance industry databases which collect and share information about you
• Insurance Ireland also have a fraud prevention website and should a statement be made about you by another it will be forwarded onto the relevant insurance provider.

When you place a risk on cover with us, your insurance company may reinsure that risk with another company as part of their risk management strategy therefore your information may be shared with them. They will use your data to decide whether they wish to provide reinsurance cover, or deal with reinsurance claims, we do not have a direct relationship with these however you should be aware that they may need to disclose your information within their group, their agents and affiliates or third-party service providers, law enforcers and regulating bodies.

If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance.  The third party has a right to recover from the insurer the amount of any loss suffered by them.  Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person who is able to provide it concerning:

• the existence of the insurance contract,
• who the insurer is,
• the terms of the contract, and
• whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract. 

We and insurers may outsource certain aspects of our business to the European Economic Area.  Under our arrangements with these service providers and insurers they are responsible for ensuring that such transfers of information are carefully managed to protect your privacy. If you would like more information regarding this, please refer to our Privacy Policy or contact us.  

If you remain concerned about the level of detail that any of the above / below has or may potentially ask you for, please do not hesitate to contact us and we will assist with the best advice possible to you due to the fact we value your business however we feel it important to make you aware of what may potentially occur.

When we ask you for certain information, it is because insurance companies need the information to perform certain validations about you, typical examples of this would include but are not limited to:

7. The Legitimate basis for Collecting your Personal Information and Contacting you

Your business is important to us. We set out below the legitimate reasons why we collect your personal data and confirm that the purposes of this data collection is always in your best interests.  

8. Sharing your Information for Fraud Prevention, Money Laundering and other offences

The data you provide will be sent to your insurance company and may be shared with other insurance companies, other third parties as well as certain statutory and other authorised bodies for the purposes of detection and prevention of fraud, money laundering and counter terrorism.

• Sharing information about you with other insurers and public bodies including the Department of Transport, Tourism and Sport, the Road Safety Authority, the Department of Finance and the Gardaí.
• Private Investigators, tracing debtors or beneficiaries, recovering debt, managing your accounts and/ insurance policies.
• Undertaking fraud searches on publicly available information as outlined above and other industry databases as outlined in Section 6 above.

9. Automated Decision Making

We search the market on your behalf, insurers use automated decision making to decide if they can provide insurance to you and on what terms.

In particular, they may use an automated underwriting engine coupled with algorithms to provide, or assist with providing, quotes including the premium that will apply to your policy of insurance, using the information we collected about you.  An insurance company uses automated decision making as it is necessary for entering into, or performance of your policy between you as the data subject and your insurer as the data controller and other uses such as authorised by law.

Profiling for marketing purposes: when we seek to contact you about other services, we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.

10. Using our Website & Online Information

We use cookies to make our website function properly, make the website more secure, provide better user experience, understand how the website performs and to analyse what works and where it needs improvement.  Where possible, we have ensured not to collect your personal data. However some performance and functional cookies required for providing quotes will use personal data which you have entered. In addition, advertising and targeting cookies may use profiling in some cases. We also use Google Business and Analytics which optimises our search engine results.  For further details on our use of cookies, on how to manage your cookie preferences and retain your privacy, please refer to the Cookie Policy on our website at www.travers.ie.

11. Your Rights in respect of your Personal Information

You have a number of rights in respect of the information stored about you, which include but are not limited to:

• Subject Access Requests for your information.
• The Right to Rectification to correct any mistakes on our records.
• The Right to be Forgotten to erase any data and/or documents you feel necessary.
• The Right to Restriction of processing which allows you not to be subject to automated decision making if the decision produces legal or other significant effects about you.
• The Right to Data Portability which allows you to move certain data to other providers.
• The Right to Withdraw your Consent.  

We may not always be able to meet a request for the above-mentioned rights to be granted as these may be overridden when processing is necessary for the performance of an in force legally binding insurance contract and/or fulfilling our legal and regulatory obligations.

You can also contact the Data Protection Commission in Ireland at www.dataprotection.ie for information about your rights.

12. Right of Access

Every person has a Right to be given a copy of his/her personal data. Under the Data Protection Acts, a Subject Access Request should be submitted in writing along with proof of your identity to our postal address for the attention of the “Compliance Officer” and we will reply within 30 calendar days. Please be specific in your request as this will assist us to complete your request promptly.  

13. How Long do we Retain your Personal Information

Data will not be held for longer than is necessary for the purpose(s) for which it was obtained.  This means that the period of time for which we store your personal data may depend on the type of data we hold.  To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

We will process personal data in accordance with our retention schedule.  For more information on our data retention policy/schedule please contact us.

14. Data Security

Travers & Co. Insurances Limited intent is to strictly protect the security of your personal information; honour your choice for its intended use; and carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction. We have taken appropriate steps to safeguard and secure information we collect online, including the use of encryption when collecting or transferring sensitive data such as credit card information.  However, you should always take into consideration that the internet is an open forum and that data may flow across networks with little or no security measures, and therefore such information may be accessed by people other than those you intended to access it.

15. Complaint and Contact Us

If you are concerned about us protecting your privacy, you can make a complaint.  We will act upon it promptly as per our privacy policy. You can contact us as set out in Section 1 ‘General’ above. If you are not satisfied with our response to your complaint, you have the right to file a complaint with the Data Protection Commissioner’s Office (“DPC”). You can find further details on the DPC website at www.dataprotection.ie. If you have any questions regarding our privacy policy, please email dataprotection@travers.ie.   

This privacy statement was last updated on 15th May 2023. 

Travers & Co. Insurances Limited trading as Travers Financial Services, Travers Insurances is regulated by the Central Bank of Ireland.