Roam insurance is underwritten by White Horse Insurance Ireland dac (“White Horse”) and provided to you through the Roam insurance Services by Thomas Cook Money Limited.
White Horse Insurance Ireland dac is owned by Thomas Cook Money Limited and both companies are part of the Thomas Cook Group.
In this policy, we refer to Thomas Cook Money Limited as “we” or “us”.
This policy covers the data that we collect from you through our Digital Channels. Read on to find out more...
We collect certain personal data about you and about any other person you include on your policy. The sort of personal data we collect is information that you provide to us, that we collect from you or observe about you, or that we obtain from other sources. Read on to find out more..
When you make a purchase or enquiry we will ask you for your name, address, e-mail address, telephone number, date of birth, security questions and certain other information (such as destination of travel). We need to collect this information in order to provide the products and other services you are requesting. We provide this information to White Horse so that they can underwrite and manage your insurance policy.
If you enter a competition or promotion, complete a survey, or if you report a problem with any of our Digital Channels, we will collect your name and relevant contact information and any other personal information you choose to give us.
If you contact us online, we may keep a record of your e-mail or other correspondence.
If, when using our Digital Channels, you search on our website or provide any of your personal data (including telephone number or e-mail address), but do not make a purchase, we will keep and use the data you’ve provided for a limited time and purpose, as mentioned below.
To help us keep your information current, accurate and complete, please ensure you tell us if anything needs to be changed.
Based on how you have used our Digital Channels in the past and your activity on our website, apps and social media channels, we collect the following personal data about you:
Details of the services we have provided to you in the past, including your previous purchases and searches, and matters related to those arrangements, such as details of your previous requirements or complaints.
We collect details of your visits to our Sites and Apps (including, but not limited to, traffic data, location data and weblogs) whether this is required for our own purposes or otherwise, and of the resources that you access. We use third party technology services, such as Google Analytics to administer these services.
We collect details of website(s) you visited before you use a link to our Sites, pages visited in our Sites, and time spent on each page.
We may collect information about your computer (or mobile device/tablet) including, where available, your IP address, operating system, device location, browser type, cookie identification numbers, for system administration purposes, marketing purposes (both our own, and third-party advertisers for whom we provide advertising services) and to report aggregate information to our advertisers. This is statistical data about our users" browsing actions and patterns, and any reports we share do not identify any individuals.
We might also receive your personal data from third party sources who collect information about you on our behalf. This includes:
If you tell a third party that you would like to receive marketing communications from us, they will securely transfer your contact details and marketing preferences to us.
If you complete any of our customer feedback questionnaires/surveys, the information you provide will be processed on our behalf and provided to us by a third party such as Trust Pilot A/S.
Your personal data is held on a combination of our own systems and systems of the suppliers we use to provide our services. Read more here...
When you give your personal data to us, some of it may be shared with other companies within the Thomas Cook group, particularly White Horse, for the purpose of providing services to you directly or on our behalf. Your personal data will also need to be given to and processed and stored by relevant third parties. These third parties include:
our card payment facilitators and other relevant third parties such as fraud investigators, that help us process customer payments or assist us in detecting and preventing fraudulent payments or claims.
regulatory authorities and state organisations e.g. the Financial Conduct Authority, Central Bank of Ireland, relevant tax authorities or law enforcement authorities.
service providers such as IT suppliers, actuaries, auditors, lawyers, data storage companies.
anyone with authorisation to act on your behalf.
Some of these third parties may be based outside of the European Economic Area (“EEA”). Organisations that are based outside of the EEA may not be subject to the same level of controls in regard to data protection as exist within the UK and the EEA. We aim only to transfer your data to third parties outside of the EEA where either:
In order for you to receive services overseas (for example, reimbursement for medical treatment received abroad), we may be required to disclose certain of your personal data to medical institutions in the UK and in other countries or to government bodies (such as immigration, border control and law enforcement). Even if it is not mandatory for us to provide information to such authorities, we may exercise our discretion to assist them where appropriate in the interests of detecting and preventing criminal activity.
We may disclose your personal information to any member of our Group for business purposes, (those business purposes include holding your data on central/shared systems for administering bookings and supporting customers in destination countries). Our Group means our subsidiaries and our ultimate holding company and its subsidiaries.
We may pass your data to relevant third parties, such as a payment facilitator Ingenico Group for the purpose of detecting and preventing fraudulent payments or bookings.
In order to provide our services to you, we use the information we hold in a number of different ways. Read more here...
We may use and process your personal information (including special category data such as information on your health specifically for insurance purposes) where we have a specific legal basis to do so under applicable national law.
The following activities are carried out by us using your personal data because it is necessary in relation to a contract which you have entered into or because you have asked for something to be done so you can enter into a contract;
Providing the services internally and through our suppliers, to ensure the services you have requested are arranged;
To communicate with you regarding your services or any other purchase;
To carry out renewal of insurance policies;
For resolving complaints and dealing with disputes;
We may use automated decision-making for medical screening purposes where we need to make an assessment of risk for certain pre-existing medical conditions. The criteria used in this assessment will enable us to determine whether we can offer you cover or whether you may be required to pay an additional premium for cover.
We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so:
To improve customer experience;
To allow you to participate in interactive features of our Digital Channels, when you choose to do so;
To ensure that content from our Digital Channels is presented in the most effective manner for you and for your computer;
To notify you about changes to our service.
To protect our business against financial loss;
For debt collection or credit vetting;
For payment card and verification (including using Google reCAPTCHA on some of our Sites to ensure only genuine customer bookings are made);
For preventing and detecting fraudulent or criminal activity.
To promote our business, improve our products and services;
To send marketing correspondence about products and services similar to those you have previously bought from us. You can opt out and object to our sending you electronic marketing information and this option will be included in every marketing message we send you. See the section ‘When and how do we use your information for marketing for more information’;
For statistical analysis and actuarial reporting;
To contact you if you make an enquiry with us on our website but do not complete a purchase to check if there was a problem or you need any assistance.
For internal research/analysis to improve the quality of our services, the products we offer and new products we are developing by:
Inviting customers to take part in surveys or customer/business discussion groups;
Using aggregated customer data to make informed decisions based on analysis of customer behaviour or other purchase trends and behaviours;
Management information purposes including risk assessment, performance reporting and management reporting.
To promote our business, brands and products and measure the reach and effectiveness of our campaigns;
To contact you with targeted advertising delivered online through social media and other platforms operated by other companies. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
We use this information in two ways:
We identify links between your attributes and your behaviours and market to others with the same attributes, in our direct marketing campaigns and through targeted advertising delivered through our Digital Channels or third party platforms;
We tailor and personalise our interactions with you to make them more relevant to your interests. These interactions include your journey around our Sites and the content that appears on it and marketing communications we send or show to you in our direct marketing campaigns and through online targeted advertising described in the paragraph above. Please see How we personalise marketing for you’ for more information;
To support any potential company sale or acquisition;
In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.
We may use and process your personal information as set out below where we have your consent to do so:
To send marketing correspondence about our products and services where we have asked for your permission to do so. See the section ‘When and how do we use your information for marketing for more information’.
We and third parties acting on our instructions, such as external law firms and their employees, may use and process your personal information as set out below where there is a legal requirement for us to do so:
For resolving complaints, dealing with disputes and legal proceedings.
To comply with relevant legal and regulatory obligations e.g. keeping proper books and records.
Where you have given consent to the processing of your data.
To find out more about our marketing communications, including when and how we may contact you and how you can opt out of marketing, please read more here...
If you have made an enquiry or purchase on one of our Sites, through a Thomas Cook store or contact centres, your personal data may be used by us in the ways the law allows, to contact you by post, electronic means (e-mail or text message) and/or by phone with information and offers relating to products or services that you can book/purchase from Thomas Cook companies. We will only do this if you did not opt out of such marketing at the point where we collected your contact details.
If you have not made an enquiry or purchase, we will only send you information and offers by e-mail or text message if you sign up (opt in) to receive such marketing, either directly through us or by telling a third party that you would like to receive marketing from us.
If you have not purchased your insurance through a Thomas Cook branded provider, we will not use your information for marketing purposes unless you have expressly opted in to this use of your information.
The type of products and services that can be booked/purchased through Thomas Cook are shown in the table below. You will only receive marketing communications about those which we think are relevant to you:
Travel and travel related services from our group companies
Insurance products from White Horse
For financial products or services from Thomas Cook Money Ltd
We will not pass your contact details to a third party that is not one of our business partners involved in providing Thomas Cook services or products for them to contact you or send you marketing communications unless you have expressly agreed that we may do so.
To try and ensure that our marketing communications and advertising are relevant to you, we work with third parties to offer a better experience to customers and potential customers. You can find out how we do this by reading more here...
Using new technologies and with the help of our advertising agencies and marketing activation platforms, we may use your personal information in the following ways:
to try to ensure any marketing communications we send to you are offering products or services likely to be of interest to you.
to tailor and track our digital marketing (for example, our internet banner advertisements) and links from our marketing partners" websites to our Sites. This digital marketing may include marketing related to Thomas Cook or marketing related to third parties to whom we provide advertising services.
Our business partners and advertising networks (including Google Double Click for Publishers) may also serve you with adverts on our Sites. We allow third parties to collect information about your online activities using cookies and other technologies. The third parties may include other Thomas Cook companies, our suppliers/business partners who collect information when you view or interact with an advert on one of our Sites, and advertising networks. We also collect information about your online activities using cookies and other technologies when you use websites other than our Sites to provide advertising services to third parties. This technology allows us to display an advert to you relating to a third party on other websites based on your page visits and other behaviours whilst on our Sites.
The information collected by these third parties might be used to make predictions about your preferences or interests and to display adverts on our Sites or across the internet appropriate to those perceived interests. Please see our Cookies Policy for more information.
We understand you might no longer want to hear from us and that’s ok. It is easy to opt-out or unsubscribe, please read more here...
You have the right at any time to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by selecting the ‘no marketing’ option on the forms we use to collect your data. You can also exercise this right at any later time by using the unsubscribe link on any marketing e-mail you receive, by following the opt-out instructions on any direct marketing communication sent by post, or by sending an unsubscribe request to: Data Protection Officer, Thomas Cook Money Limited, 3rd Floor South Building, 200 Aldersgate, London EC1A 4HD.
Please note – when you unsubscribe from marketing in respect of insurance, this opt-out will apply only to Thomas Cook Money Limited. If you receive marketing directly from a Thomas Cook Holiday Company and if you wish to opt-out from their direct marketing, you will need to follow the instructions on their website or follow unsubscribe notices in their marketing communications.
You have a number of rights in relation to your personal information under data protection law. To find out more, please read here...
Your Right to Access Your Personal Information
You have the right to make a Data Subject Access Request in many circumstances. That is a request for access to the personal information that we hold about you. If we agree that we have to provide personal information to you (or someone else on your behalf), we’ll provide it to you or them free of charge.
We may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. That may include information about your previous purchases. If someone is acting on your behalf, they will need to provide written and signed confirmation from you that you have given your authority to that person/company for them to make the request. We will ask for this to be provided before we give you (or another person acting on your behalf) a copy of any of your personal information we may be holding.
Please see the section titled ‘How to Contact Us’ if you need to make a Data Subject Access Request.
Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if you change your name or address/e-mail address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us using the details below.
Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out in section above titled ‘How do we use your information when providing our services to you’, you may withdraw your consent at any time. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, please see the section titled ‘What you need to do if you don’t want our marketing communications’ for further details.
If you would like to withdraw your consent to us processing any information concerning medical conditions, disabilities and special requirements, please contact us using the contact details below. Please note if you ask us to stop processing this information, it may mean we won’t be able to provide all or parts of the services you have requested. If we have to cancel your booking or other purchase as a result, you may incur a cancellation charge.
If you withdraw your consent, our use of your personal information before you withdraw is still lawful. Please note that exceptions may apply where we may need to continue to process your data e.g. in order to fulfil other legal obligations or legitimate business interests.
Objecting to our use of your personal information
Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), you may object to us using your personal information for these purposes by e-mailing or writing to us at the address provided at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection law, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by e-mailing or writing to us at the address at the end of this policy. Provided we do not have any continuing lawful reason to continue processing or holding your personal information, we will make reasonable efforts to comply with your request. Please note that exceptions may apply where we may need to continue to process your data e.g. in order to fulfil other legal obligations or legitimate business interests.
You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. We may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Transferring your personal information in a structured data file
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out in section titled ‘How do we use your information when providing our services to you’, you may ask us to provide you with a copy of that information in a structured data file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if it contains the personal information of other individuals or we have another lawful reason to withhold that information.
How to contact us:
Any subject access request can be made in writing to:
Data Protection Officer, Thomas Cook Money Limited, 3rd Floor South Building, 200 Aldersgate, London EC1A 4HD.
Alternatively you can make a subject access request by e-mail to: firstname.lastname@example.org
Once you have made your request and provided us with the information we need to begin a search for the data we hold on you (including proof of identity), we will have 30 days to respond.
Making a complaint
We encourage you to contact us if you have a complaint and we will seek to resolve any issues or concerns you may have.
You have the right to lodge a complaint with the data protection regulator where you believe your legal rights have been infringed, or where you have reason to believe your personal information is being or has been used in a way that doesn’t comply with the law. The contact details for the Information Commissioners Office are available on the ICO’s website.
If you want to find out more about our data retention policy, please read more here...
Where you’ve made a purchase with us, your personal information will be retained to ensure we provide the best possible customer service to you. For example, if you purchase a product from us, we will keep your data for up to 7 years. We will keep your data for marketing purposes for up to 2 years. In some cases, such as where there is a dispute or a legal action we may be required to keep personal information for longer. We also retain your personal data for legal and audit purposes only for as long as necessary and in accordance with any retention period required by law.
We take data security very seriously, to find out our approach to this please read more here...
The transmission of information via the internet is not completely secure, and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites, therefore any transmission is at your own risk. Once we have received your information, we will take all reasonable steps to keep your personal data secure and to try to prevent any unauthorised access, use or loss of your data, by putting in place appropriate security measures and limiting access to those who have a business need to know. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.
We have a process to deal with any suspected personal data breach and will notify you and the ICO of a breach where legally required to do so.
Thomas Cook Group Sites and Apps include links to other websites which include privacy policies of their own. To learn more about this, please read here...
Thomas Cook Group Sites and Apps contains links to and frames of websites of our principals, suppliers, advertisers and other third parties. You can tell when a third party is involved in supplying a product or service you have requested because their name will appear with ours. If you follow a link or otherwise use any of these other 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 these third-party websites. Please check these policies before you submit any personal data to these websites.
Some cookies are essential to make our Sites work properly and to allow you to make purchases and enable us to fulfil your purchase requests
Customer Experience Cookies (Analytics, Customisation & Tracking)
These types of cookies help us to provide you with a good experience when you browse our Sites and allow us to track your experience between different devices to improve our Sites or the way we provide our service to customers.
Third party adverts on our Sites and social media: This type of advertising is intended to provide you with a selection of products/services that you’ve viewed on other third party websites, or social media channels, which are presented to you by our agency when you visit our Sites or social media channels. The adverts may feature variations on the products/services that might be considered relevant to your browsing history on these other third party websites.
Thomas Cook adverts on third party websites: This type of advertising is intended to provide you with a selection of related products/services that you’ve viewed on our website, which are presented to you by our agency when you visit other selected websites or social media channels. The adverts may feature different Thomas Cook products/services that might be considered relevant to your browsing history.
We use advertising solutions delivered by Google DoubleClick for Publishers (DFP) and Criteo to serve you these advertisements. Where we share data for the purposes mentioned above, it is encrypted and does not include your name.
This list identifies the main cookies set by our websites, and what each is used for.
Category: Advertising and Marketing
Description: These may be set from a few different domains, including google.com, doubleclick.net, googlesyndication.com, or googleadservices.com, or the domain of our partners’ sites. Some of our advertising products enable our partners to use other services in conjunction with ours (like an ad measurement and reporting service), and these services may send their own cookies to your browser. These cookies will be set from their domains.
These cookies are used to allow us to track the adverts that users click on to reach the website and assist us in showing you customised adverts when you visit other websites. You can find more information about this type of advertising at www.youronlinechoices.com where you can also find information about how to control your online behavioural advertising preferences and options to turn off behavioural advertising for individual companies (Please note turning off behavioural advertising will not stop you seeing advertisements online or stop cookies being used. You should follow the instructions at www.aboutcookies.org to adjust the privacy settings on your web browser if you wish to turn off cookies).
The DoubleClick Floodlight Counter tag allows us to count the number of times that users have visited a particular page after seeing or clicking one of their ads.
Summary of cookies:
Registers a unique ID that identifies a returning user"s device. The ID is used for targeted ads. Sometimes, cookies contain an additional identifier seemed to cookies’ ID, such identifier is used to identify an advertising campaign which has been sent to a specific user but DoubleClick does not keep personal data information in the cookie.
Expires after 2 years
Used by Google DoubleClick for re-targeting, optimisation, reporting and attribution of online adverts
Expires after 1 hour
This cookies allows for relevant advertising, based on your visit to our website, to be displayed on other websites.
Expires after 2 years
Type: Google Analytics
Description: These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Understanding how customers use our website, enables us to identify what needs to be improved on the website to better serve our customers. Read about Google privacy overview at Google Support.
Summary of cookies:
This cookie is used by google analytics to distinguish users on the website.
Expires after 2 years
This cookie is used by google analytics to distinguish users on the website
Expires after 24 hours
Expires after 2 years from set-up or update
Expires after 30 minutes from set-up or update
Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.
Session based cookie that expires when your session ends or you leave our site.
Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.
Expires after 2 years from set-up or update
Expires after 6 months from set-up or update
If you choose to remove cookies, parts of website you are on may not work properly or your use of the website may be impaired.
If you choose to use the website you are on without declining any non-essential cookies, then your use will constitute implied consent to the non-essential cookies that are set.
You can accept or decline advertising, and customer experience (analytics, customisation and tracking) cookies at any time by using the ‘Manage Cookies’ link above.
You can opt-out of third-party advertising networks using your information for interest-based advertising. Our Sites participate in Google DoubleClick for Publishers (DFP) partner network, you can opt-out of this here: Google Double Click Opt Out
You will need to opt-out on each device you use to access our Sites.
Your information will not be shared with our third party advertising network partners for the purpose interest-based advertising if you opt-out, however, you will continue to receive interest-based advertising from Thomas Cook and its business partners when using one of our Sites.
Please note these opt-out mechanisms use a cookie on your device, and if you clear the cookies from your browser it will ‘forget’ the opt-out.
Alternatively, you can review cookies by accessing the preference panels from your browser's main menu (usually found under ‘Edit’, ‘Tools’ or ‘Options’). Do not track (DNT) is a feature offered by some browsers, with some newer browsers offering it as default. If you enable it, it sends a signal to websites to request that your browsing isn't tracked, for example by third party advertisers or social networks, or analytic companies. No industry-wide agreed standard to determine how DNT requests should be managed has been put in place, so our Sites don’t currently support DNT requests. Until that standard is established, we'll continue to review DNT and other new technologies, but won't respond to DNT requests.