Total Health Cover: Privacy and Security
Here at Total Health Cover we care about your privacy and we respect your privacy rights.
1.1 Our website www.Total Health Cover.ie, including all the webpages containing that address, (the “Total Health Cover website”) is operated by PHI Consulting (Ireland) Ltd, 8 South Strand, Convent Lane, Rush, Co. Dublin [Company Number: 481527].
1.2 Total Health Cover is regulated by the Central Bank of Ireland.
1.3 Our agreement with you (together with our terms and conditions, any terms and conditions of a Total Health Cover product, and any other documents referred to in these documents) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, including the data collected in relation to contracts of insurance with insurers for which we act as investment and insurance brokers, which we allow the Total Health Cover website users to request, contract for, manage, claim in respect of and otherwise deal with via the Total Health Cover website from time to time at our sole discretion (each a “Total Health Cover Product”).
1.4 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. How we collect information on the Total Health Cover website
2.1 When enquiring about a product, you may be asked to provide information to us. We will inform you at the time of collecting information from you whether you must provide the information to enter into a contract for a healthcare product or whether the provision of information requested by us is optional. In most cases, you will be offered a link to link directly to the healthcare provider of the product of interest and you will deal directly with that provider.
2.2 We may collect and process the following data about you.
2.2.1 If you contact us, we may keep a record of that correspondence.
2.2.2 Information that you submit when you apply for a healthcare product, which may include but is not limited to your name, email address, payment details, renewal date(s) and date of birth.
2.2.3 Where you are applying or using our website to deal with a healthcare product in connection with life assurance or health insurance, details concerning your health, sexual preferences, age and health status. Other sensitive data may be collected in the event of a claim, details of which will be provided at that time.
2.2.4 Other information that you submit when you use the Total Health Cover website.
2.2.5 Details of transactions you carry out through Total Health Cover; and
2.2.6 Details of your visits to Total Health Cover including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
2.2.7 Details of your interest in other health care products that we may subsequently market to you
2.2.8 Your contact details to receive our regular e-zine on the healthcare market (you must register
for this option).
3. Uses made of the information
3.1 We use information held about you in the following ways:
3.1.1 To ensure that content from Total Health Cover is presented in the most effective manner for you and for your computer.
3.1.2 To provide you with information, products or services that you request from us.
3.1.3 To quote or process your purchase of a healthcare product on behalf of an insurer.
3.1.4 To process your request for a quote, or your offer to enter into a contract for a healthcare product, on your behalf, and to submit your data to an insurer or insurers on your behalf for this purpose.
3.1.5 To process your claim for a payment in connection with a Total Health Cover product on behalf of an insurer and also on your behalf.
3.1.6 To provide you with information regarding our other products or services which we feel may interest you. We may use your email address for this purpose and to send you updates or news regarding Total Health Cover and our services. You may choose not to receive emails of this type by opting out using the tick box provided in our data protection declaration.
3.1.7 To provide you with information regarding products or services of third parties which we feel may interest you and where you have consented to be contacted for such purposes.
3.1.8 To carry out our obligations arising from any contracts entered into between you and us, including any related to a Total Health Cover product.
3.1.9 To deliver and maintain a high quality service.
3.1.10 To allow you to access the Total Health Cover website and to participate in interactive features of our service, when you choose to do so; and
3.1.11 To notify you about changes to our services, to a Total Health Cover product or to the Total Health Cover website.
3.1.12 Please note that telephone calls may be recorded for quality control and training purposes.
4. Disclosure of your information to other people
4.2 If you provide personal information to us, you understand and agree that we may disclose your personal information to the following third parties:
4.2.1 Any insurer that is a party to a Total Health Cover product that you have applied for or contracted for.
4.2.2 if you have indicated when applying for a Total Health Cover product or at any time during your time as a user of the Total Health Cover website, that you are happy to receive information or promotions from selected third parties about goods and services which may be of interest to you, you consent to third parties that we choose sending you such offers or information. You may opt out of receiving such offers or change your preferences at any time.
4.2.3 Any member of our group of companies, which means our subsidiaries, our partner providers, our ultimate holding company and its subsidiaries.
4.2.4 Any co-insurers of the insurers for which we act as brokers.
4.2.5 Our advisors.
4.2.6 Where you are applying or using our website to deal with a Total Health Cover product in connection with an employer, affinity scheme or any other organisation.
4.2.7 To a credit referencing agency and/or to other insurers through various databases to help us check information provided and also to prevent fraudulent claims.
4.2.8 To the prospective seller or buyer of any business or assets related to the Total Health Cover website, a Total Health Cover product or all or part of [Total Health Cover];and
4.2.9 To a third party if we are under a duty to disclose or share your personal data with that third party in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements, or to protect the rights, property, or safety of our group of companies, Total Health Cover, insurers related to a Total Health Cover product or others. This includes exchanging information with third parties such as Government agencies for the purposes of fraud protection and credit risk reduction.
4.3 We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to prevent such information sharing at the time that we notify you.
4.4 We do not disclose personal information about you to third parties (including advertisers or marketing companies) unless you have consented to that disclosure, but we may provide them with aggregate anonymised information about users of the Total Health Cover website or customers of Total Health Cover products. For example, we may inform an insurer advertising on the Total Health Cover website that 50 men aged under 25 have clicked on their advertisement for car insurance that was displayed on the Total Health Cover website on any given day, or we might inform third parties regarding the number of unique users who visit the Total Health Cover website, the demographic breakdown of our Total Health Cover website users or the activities that visitors to Total Health Cover engage in while on the Total Health Cover website. We may also use such aggregate anonymised information to help advertisers reach the kind of audience they want to target (for example, women in Dublin) when displaying advertisements on the Total Health Cover website.
4.5 It may be necessary to transfer your personal information to other group companies or service providers located in countries outside of the European Economic Area (EEA). This may happen where our servers or suppliers and service providers are based outside of the EEA or where you use our services and products while visiting countries outside of the EEA. The data protection and other laws of these countries may not be as comprehensive as those in Ireland or the EU but in these instances we will take steps to ensure that your privacy rights are respected. You agree that we may transfer your personal data on that basis.
5. Security and control of your personal data
5.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of Total Health Cover, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. You are responsible for the security of your password and our terms and conditions deal with this in more detail.
5.3 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Total Health Cover; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. You acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
6. Links to third party websites
6.1 Total Health Cover may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates as well as third party websites to which we have no affiliation. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for the activities on those websites.
7. IP addresses and cookies
7.1 We may collect information about your computer, including (where available) your IP address, alphanumeric IDs, operating system, browser type, information regarding the volume and status of data transmission, click-through statistics, the name of the domain and host from which you access the internet and the date and time you access portions of the Total Health Cover Website, for system administration and statistical purposes. This is statistical data about our users' browsing actions and patterns, and we do not use them to identify any individual, except if required by the law.
7.2 For the same reason, we may obtain information about your general internet usage by using a cookie file (which may include a flash cookie file) which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. On revisiting the Total Health Cover website our computer server will recognise the cookie, giving us information about your last visit. They help us to improve the Total Health Cover website and to deliver a better and more personalised service. They enable us:
7.2.1 To estimate our visitor size and usage pattern.
7.2.2 To store information about your preferences, and so allow us to customise the Total Health Cover website according to user or visitor preferences; and
7.2.3 To speed up your use of the Total Health Cover website and enquiries made of the website.
8. Access to information and updating, verifying and deleting personal data
8.1 You agree to keep Total Health Cover and any insurer with which you have contracted for a Total Health Cover product informed of any changes to your personal data provided to us and them via the Total Health Cover product.
8.2 At any time, you can make a written request to have access to all the personal information that we hold about you. We will provide this information to you and may request a small administrative charge. Please send your written request to Compliance Dept, PHI Consulting (Ireland) Ltd, 8 South Strand, Convent Lane, Rush, Co. Dublin
10. User feedback and complaints