Privacy policy

2.1. From you - Most of the personal data we collect comes directly from you when you use our website, channels, applications, or other services operated by or on behalf of us. In this Privacy Policy, we refer to the website, channels, and applications collectively as the "Site", and to the services available through them as the "Services".

2.2. From our partners - If you purchase a product from one of our partners whose products are shown on our Site then they may send us information they hold relating to the product(s) you have purchased. This allows us to track sales and improve our Services.

2.3. From our channel operators - whilst the majority of the channels on our Site are run by us, some of our channels are designed, maintained and/or run for us by our trusted channel operators. We may receive your personal information from our channel operators and use it in accordance with section 4 below. Where our channel operators collect your personal information on a channel which is maintained by them, they will be acting as the data controller of your personal information. You can view our list of channel operators and links to their privacy policies.

2.4. From our suppliers - We will sometimes use other companies to collect and process your personal information on our behalf, for example we may use IT service providers or market research agencies. Where we use third parties, we will make sure that they commit to keep your information safe.

3.1. We collect and process limited personal data from you when you use the Site. The personal information we may collect when you use the Services may include your email address and postcode if you sign up to receive emails from us. We use this data to provide your travel deals and travel tips.

3.2. In order to provide you with a travel insurance quote we pass you over to Moneysupermarket who operate the travel insurance price comparison service for us.

3.3. In the course of providing the Services to you, we may also store information about how you use our Site, for example, the pages viewed, the website or marketing communication from which you came to visit our Site, links you select in emails where this tracking is used, information about your subsequent journey through the Site, changes you make to information you supply to us, details of the quotes you request and your transactions.

3.4. We do not knowingly collect or store personal data about children under the age of 16. If you are under 16, please ask your parent or legal guardian to use the Services and provide any required personal data on your behalf.

3.5. If you are providing us with another person's information (for example where you request a policy which includes another person as a joint policyholder or obtaining quotes for a family member) you should first, ask them to read this Privacy Policy and our Terms of Use. By giving us information about another person you are confirming that you are authorised to do so and that they understand how their details will be used.

3.6. We may monitor or record your calls, emails, SMS or other communications but we will do so in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training (e.g. where you call our customer services help line), to prevent unauthorised use of our telecommunication systems and Site, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime.

3.7. In order to ensure the Services we provide you continue to meet your needs we may ask you for feedback on your experience of using the Site. Any feedback you provide will only be used as part of our programme of continuous improvement and will not be published on the Site.

Note that it is your responsibility to check and ensure that all information, content, material or data you provide on the Site is correct, complete, accurate and not misleading and that you disclose all relevant facts.

We may use your personal information:

4.1. to enable you to access and use the Services including:

4.1.1. passing it to our partners including companies whose products or services are included on our Site, with a view to them providing you with an online quote. When our partners use your personal information to provide a quote they will act as data controllers of your personal information – you can see links to lists of our partners in section 5.1.3 below;

4.1.2. to process a transaction between you and a third party;

4.1.3. to track sales, which may involve us sharing data with your product provider relating to the product(s) you have purchased; and

4.1.4. to enable you to share our content with others, e.g. by using any 'Email a friend' or 'Share this' functionality on our Site.

4.2. to communicate with you, including some or all of the following:

4.2.1. sending you information about products and services which we think may be of interest to you – We will only send you this information if you give us your consent for us to do so. We will contact you via email or by other electronic means such as via social and digital media - this may include new product launches, newsletters and opportunities to participate in market research;

4.2.2. sending you a confirmation email of your quote - when you obtain a quote with us, you will automatically be sent confirmation of your quote by email so that you have a record of it and can easily retrieve your quote in the future;

4.3. to personalise and improve aspects of our Services including to improve our recommendations and insights. The information we collect helps us tailor our content and improve our suggestions to you and other users about products or services that may interest you or them.

4.4. for research, such as analysing market trends and customer demographics - If you’ve given us permission, we may contact you to ask you to assist us with market research by asking you questions about the Services and asking you if you would like to complete a review of the Services. We may sometimes ask market research companies to contact you on our behalf.

4.5 to create and use aggregated, anonymised or statistical information about use of our Services and partner performance for reporting, analytics, benchmarking, product improvement and business insight, including through IceIQ. This information will not identify you.

When you use any of our Services, we may disclose your personal information to the following parties:

5.1.1. other members of the Ice Travel Group, where this is necessary for the purposes described in section 4, including to operate and improve our Services, administer our business and support reporting and analysis;

5.1.2. our channel operators – When you use the Services we may share your personal information with our channel operators for them to use it in accordance with section 4 above. Where our channel operators collect your personal information on a channel which is maintained by them, they will be acting as the data controller of your personal information provided in relation to a quote. You can view our list of channel operators and links to their privacy policies.

5.1.3. our partners including companies whose products or services are included on our Site:

In order to display quotes on the Site we will send your personal information to our panel of insurance partners. We need to send them your personal information so that they can generate a quote for us to display on the Site. When these companies use your personal information in this way, they will be acting as data controllers of your personal information which means that they are in charge of how they handle your data and we are not responsible for this.

If you click through to any of our partners websites, provide them with additional information on their websites and/or if you decide to purchase a product from any of our partners then they will be data controllers of your personal information and you should read their own privacy policy which you should find on their website.

You can view a list of our travel partners.

5.1.4. Where permitted or required by law or regulation, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account in order to comply with legal or regulatory requirements for example:

5.1.4.1. if required to do so by any court, the Financial Conduct Authority, the Competition and Markets Authority or any other applicable regulatory, compliance, Governmental or law enforcement agency;

5.1.4.2. if necessary, in connection with legal proceedings or potential legal proceedings;

5.1.4.3. in connection with the sale or potential sale of all or part of our business; and/or

5.1.4.4. if we reasonably believe false or inaccurate information has been provided and fraud is suspected, details may be passed to fraud prevention agencies to prevent fraud and money laundering.

5.2. How do our partners use your personal information and who might they share it with?

In order to provide you with a quote, our partners may exchange information about you with other companies and/or carry out checks with various databases. Our partners act as data controllers in respect of this use of personal information and we are not responsible for it. We have set out below some of the common ways they will share your information:

5.2.1. Some of our partners will use your personal information to assess your circumstances (including information about any third party who is named on the policy) and verify the information that you have provided before providing a quote to you;

5.2.2. Some partners may carry out checks against data they already hold on you, (or is held by the company whose brand they administer the product for, or members of their group of companies) such as data from existing products, account data, data from previous product transactions, accounts you may hold with them or loyalty scheme data to share with insurers in order to determine your premium.

Some travel insurance partners may carry out checks with fraud prevention and credit reference agencies, both when you first run your quote and when we run an annual renewal quote. Insurers generally run these checks to ensure that they and credit partners have the necessary facts to assess your insurance risk, verify your identity, help prevent fraud and to provide you with their best premium and payment options). If partners do these checks, they will be quotation searches only and do not show up on your credit report in the same way that a ‘hard’ check does but will be visible to other organisations. Both public data (e.g. the electoral roll) and private data (e.g. your personal credit history) may be checked in this way;

5.2.3. Some of our partners may also check public and private higher education sources to obtain information about your educational background; and

This information exchange allows our partners to verify the information that is provided during the quote process (including information about any third party who is named on the policy) and also helps to detect fraudulent claims. Our partners may also use the data relating to your quotes and your personal information to create and improve the products and services they offer and to develop and improve their processes, credit risk systems and policies, so they can better meet the needs of their customers.

If you decide to enter into a contract with one of our partners via the Site, the information you have provided to us, together with any further information requested by, and supplied by you or us to the partner, will be held by the partner for the purposes set out in their privacy policy and they will act as data controller of your personal information. Therefore, you are strongly advised to read your chosen provider's privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the contract. We have no responsibility for the uses to which a provider puts your personal information.

We do not make decisions about you based solely on automated processing that produce legal effects or similarly significantly affect you. Our partners may use automated processes when generating quotes or assessing applications. Where they do so, they act as controllers and their privacy policies explain the logic involved, the significance and the possible consequences for you.

We will only collect and use your personal information in accordance with data protection laws. Our legal grounds for processing your personal information in the ways described in this Privacy Policy are as follows:

6.1. Performance of a contract - In order to provide you with the Services and manage your account we will: (i) search the websites of our partners to get you the best quotes and/or access information required to provide you with the relevant Service from our third party partners (as described herein for the relevant Service); (ii) process any transaction between you and a third party; and (iii) manage, run and administer your account. When we do this we are processing your personal information because it is necessary to perform the contract that we have in place with you to provide you with our Services.

6.2. Consent – We will only send you certain marketing emails or alerts if you have confirmed that you are happy to receive this material. Where we have asked for your consent, we will only collect and process your personal information if you have given your consent for us to do so.

6.3. Legitimate interests – We may process personal data where this is necessary for our legitimate interests or those of a third party, provided that those interests are not overridden by your interests, rights, or freedoms. Our legitimate interests include communicating with you about the Services, personalising and improving the Services, protecting and operating our business, and understanding Service use, partner relationships, and business performance, as described below.

6.3.1. to communicate with you about the Services for example, if you run a package holiday, travel insurance or car hire enquiry, we will send you the results via email.

6.3.2. to personalise and improve our Services for example, we may use your personal information to personalise aspects of our service, including to inform you about products and services we think may be of interest to you (this will not include sending you marketing communications unless you have given us consent to receive these); and to allow you to use our eligibility checker services. We constantly aim to improve our Services to you and using your personal information in this way helps us to do this.

You have the right to object to our use of your personal information for these legitimate interests. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we are continuing to process your personal information. Please contact our Data Request Team at data.protection@icetravelgroup.com if you wish to exercise this right.

6.3.3 to understand and improve our Services, partner relationships and business performance, including by creating aggregated, anonymised or statistical information for reporting, analytics, benchmarking, product improvement and business insight.

A cookie is a very small text file placed on your computer or device. Web browser cookies may store information such as your IP address or another identifier, your browser type, and information about the content you view and interact with on digital services. By storing this information, web browser cookies can remember your preferences and settings for online services and analyse how you use them. To learn more about cookies, see ,www.allaboutcookies.org or www.google.com/policies/technologies/cookies/.

We use cookies and similar technologies, including pixels, tags and online identifiers, to operate our Site, remember choices, understand how the Site is used, improve our Services and, where permitted by your choices, support advertising and personalised content.

Some cookies are strictly necessary and cannot be switched off through our cookie consent tool because they are needed for the Site to function or to provide services you request.

Other cookies and similar technologies, including Performance, Functional and Targeting Cookies, will be used in accordance with our Cookie Policy, the cookie banner and your cookie choices.

We use analytics tools, such as Google Analytics, to understand how visitors use our Site, measure performance, and improve our Services. Depending on your cookie choices and the configuration of those tools, they may collect information about your device, browser, interactions with the Site, and inferred demographic or interest categories. For more information about how Google uses information from sites or apps that use its services, see Google’s Privacy and Terms.

Cookies help us to:

7.1. understand browsing habits on the Site; and

7.2. understand the number of visitors to the Site and the pages visited. For more information on the cookies we use, please see our Cookie Policy.

8.1. Advertisements on our Site – Advertisements displayed on our Site may be delivered by us or on our behalf by third-party advertising companies. Where required, advertising cookies and similar technologies are used only in accordance with the choices you make through our cookie consent tool. These technologies may recognise your browser or device and help select advertising likely to be relevant to you. For more information, including how to change your choices, see our Cookie Policy.

If you would like more information about online advertisements and your choices about how this information may be used by these companies, please click here http://www.youronlinechoices.com/uk/your-ad-choices.

Subject to your cookie choices, we and third parties, including Google, may use cookies and similar technologies to measure advertising, personalise content, and show relevant advertisements on third-party websites. You can manage or change your choices at any time through our cookie consent tool and the Google Ads settings described above.

Your personal information’s security is very important to us. This is why, where it’s appropriate, our Site uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure. Certain information, for example, your credit card details, is encrypted to minimise the risk of interception during transit.

It might sometimes be necessary for us or our suppliers to transfer your personal information outside the UK. Where the destination is not covered by UK adequacy regulations, we will use an appropriate safeguard permitted by UK data protection law, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, and carry out any required transfer risk assessment. You can contact our Data Request Team for further information about the safeguard used for a particular transfer and how to obtain a copy.

Any electronic marketing or communications we send you will include clear and concise instructions to follow should you wish to unsubscribe at any time. You may also amend your marketing preferences by accessing your personal details via the link received in emails or by emailing us at data.protection@icetravelgroup.com.

Should you no longer wish to be contacted by us, you can advise us at any time by contacting our Customer Services team, by emailing customerservices@icetravelgroup.com.

If you no longer wish to be contacted by providers for marketing purposes, please follow the instructions in their marketing communications, or consult their privacy policies for further information about unsubscribing.

You have certain rights under data protection legislation in relation to the personal information that we hold on you including:

11.1. Right to access: the right to a copy of the personal information we hold about you. We’ll ask you to describe the information you require, as well as letting us know about any other email addresses you’ve used on our Site, to enable us to trace your personal information. Depending on the nature of your request, we may also ask you for your full name, your date of birth and your full address and documents to allow us to verify your identity. Requests for copies of your personal information will be dealt with within one month, unless your request is complicated or if you have made a large number of requests. In these circumstances it may take us longer to deal with your request, in which case we will let you know if we need longer than one month to respond;

11.2. Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete. Requests for us to correct your personal information will be dealt with within one month, unless your request is complicated or if you have made a large number of requests. In these circumstances it may take us longer to deal with your request, in which case we will let you know if we need longer than one month to respond. If we believe that your personal information is accurate, we will let you know that we will not be amending your personal information and why;

11.3. Right to erasure: the right to request that we delete or remove your personal information from our systems. Data protection laws give exceptions to this right which, if applicable, we will explain in our response to you;

11.4. Right to restrict our use of your information: In some circumstances you can ‘block’ us from using your personal information or limit the way in which we can use it;

11.5. Right to data portability: the right to request that we move, copy or transfer your personal information;

11.6. Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling to inform our market research and customer demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we’re continuing to process your personal information.

To make enquiries or exercise any of your rights set out in this Privacy Policy please contact our Data Requests Team by emailing us at data.protection@icetravelgroup.com.

If you have any concerns about how we handle personal data, you should contact our Data Request Team at data.protection@icetravelgroup.com. We will investigate your complaint and respond in accordance with applicable data protection law.

If you are unhappy with our response, or if you believe our processing of your personal data infringes applicable data protection law, you have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. Further information about how to make a complaint is available at: https://ico.org.uk/make-a-complaint/

We will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted (unless a longer retention period is required or permitted by law).

Generally, you can expect us to keep your personal information while you use the Site. Where you have applied for or purchased products or services via the Site, we will need to keep your personal information for longer for accounting purposes - up to six (6) years following the date on which it is provided to us.

If one of our partners processes your data in order to provide you with a quote they will be acting as data controller but they should only hold that data for so long as is reasonable in relation to providing you with that quote.

If you purchase a product then the service provider will keep your personal information in accordance with their own retention periods and so you should check their own privacy policy for further information.

Even if you delete or ask us to delete your personal information it may persist on backup or archival media for legal, tax or regulatory purposes.

We reserve the right to amend or modify this Privacy Policy at any time, and any changes will be published on the Site. The date of the most recent revision will appear on this page. If we make significant changes to this policy, we may also notify you by other means such as sending an email. Where required by law we will obtain your consent to make these changes.