Privacy Policy
Effective Date: April 19, 2023
PURPOSE
This Privacy Policy governs data collection and use by Detour Travel Protection, LLC (“Detour Travel”) together with any of its subsidiaries, affiliates and assigns (collective, the “Company,” also referred to herein as “We,” “Us,” or “Our”) in connection with all personal information, sensitive data or other information communicated to Us through the use of Our Website (Detourinsurance.com) or as otherwise provided in connection with any transactions between You and Us.
This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person (“Personal Data”) that is collected through the Services (as defined below) We provide. Please read this Privacy Policy carefully, as it includes important information regarding Your Personal Data and other rights You may have with respect to Your Personal Data.
Protecting Your personal information is our priority.
The Company is a service provider/data processor utilizing various Web-based technologies to service its customers (“Services”). Having accepted this Privacy Policy by engaging in a transaction through our Website or otherwise proceeding with your purchase of Company Services, You are acknowledging and agreeing to the following:
You have received the Company’s Privacy Policy;
You have been advised of the specific policies and procedures that the Company will follow in the course of processing any of Your Personal Data that You may provide;
You have been advised of Your rights under U.S. “Privacy Laws,” which include U.S. state data protection and privacy laws, such as the California Consumer Privacy Act of 2018; the California Privacy Rights Act of 2020; the California Insurance Information and Privacy Protection Act of 2009; the Virginia Consumer Data Privacy Act of 2021; and similar such laws as may come into effect as of the date You provided consent or thereafter;
You Consent to the processing of your Personal Data in accordance these policies and procedures (as further described below), and you acknowledge Your rights to: a) withdraw Consent under the circumstances described below; b) access, correct, or request deletion of certain Personal Data provided to the Company in accordance with the U.S. Privacy Laws; and c) opt out from certain specific uses of Your Personal Data as detailed below.
“Non-Personal Data” as used in this Privacy Policy is any information that does not relate to a person and/or cannot be used to identify a person. When You interact with the Services, we may collect Non-Personal Data. The limitations and requirements in this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Data do not apply to Non-Personal Data.
PERSONAL INFORMATION WE COLLECT
In order to provide you with the Company’s Services, We may collect from You, or other third parties that You have authorized to collect and transfer to Us on Your behalf, personally identifiable information, such as your:
- First and Last Name
- Billing Address
- E-mail Address
- Phone Number
- Billing or Payment Information (e.g., credit card billing information)
- Information about your transaction or business with Us
- Information about any claim You may submit
- Information about Your website usage and activity (e.g., IP address, browser data)
- Any other information provided to us by You or on Your behalf
We will only collect Personal Data to the extent it is necessary to perform the business purpose for which it was collected, namely, for purposes of insurance policy issuance, which may include administering, processing and providing You the purchased insurance policy, serving and processing Your policy or claims, or for compatible and related purposes such as internal research for technological development, detecting security incidents and fraud prevention, and performing customer service, advertising or marketing. Such Personal Data collected will only be used for those purposes and not in a manner incompatible with those purposes. Further, the Personal Data collected is adequate, relevant and limited to what is necessary in relation to the specified purposes for which it is processed. If you purchase the Company’s Services, we may collect billing and credit card information. This information is used to complete the insurance policy purchase transaction and confirmation of same. We may transfer Your credit card information to Our payment processors and do not store credit card information on Our own servers. In transferring Your Personal Data to the payment processor, We have an agreement with the payment processor that they will abide by and accord You substantially the same rights as set forth in Our Privacy Policy. We do not collect any Personal Data about You unless You voluntarily provide it to Us or another third party who You have authorized to collect and transfer such Personal Data to Us on Your behalf. However, You may be required to provide certain Personal Data to Us when You elect to use certain Services available on the Company’s Website. These may include: (a) providing Us with travel details; (b) submitting Your credit card or other payment information when ordering and purchasing Services on Our Website; (c) providing Us with various types of Personal Data (may include medical information, where needed) as part of processing any insurance claims. When You use the Services or otherwise submit Personal Data to Us, We may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. In such instances, We will treat any combined data as your Personal Data until such time as it can no longer be associated with You or used to identify You. All Personal Data is collected in a consistent format in order to ensure the quality of data in Our systems. We will use Your information to communicate with You in relation to Services You have requested from Us. We also may gather additional Personal or Non-Personal Data in the future in order to perform services purchased by Our customers.
USE OF YOUR PERSONAL DATA
The Company collects and uses Your Personal Data to operate its Website and deliver the Services You have requested. If You decline to consent to the Company’s use of Your Personal Data, the Company will be unable to initiate or continue any Services. If consent is withdrawn after Services have been initiated, any Service previously agreed upon may be terminated as if such Services had never been provided.
CHILDREN
Our Website and Services do not target and are not intended to attract anyone under the age of 13. The Company does not knowingly solicit Personal Data from children under the age of 13. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data without their permission. If You have reason to believe that a child under the age of 13 has provided Personal Data to Us, please email privacy@detourinsurance.com, and We will endeavor to delete that information from Our systems.
SHARING INFORMATION WITH THIRD PARTIES
When You purchase Services from the Company, We may provide the Personal Data to Our underwriting partners only for the limited and specified purpose of policy issuance, consistent with the consent You have provided. Upon written request, We will identify the specific underwriting partner with whom We have shared any of Your Personal Data. We share Personal Data with insurance underwriters with whom We have an agreement that they will abide by and accord You substantially the same rights as set forth in Our Privacy Policy.
Entities with which we regularly anticipate sharing Your Personal Data include: Our insurance and protection partners: Co-ordinated Benefits Plan, Nationwide Insurance, WeatherPromise and all others as needed to conduct insurance business.
Except as otherwise required or allowed by law (e.g., for fraud prevention or other legal / regulatory inquiries), We do not share, sell, use or otherwise disclose your Personal Data for any purpose other than for performing the Services consistent with the business purpose.
The Company does not sell, rent or lease its customer lists to third-parties.
LEGAL REQUIREMENTS
The Company may disclose Your Personal Data, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on the Company or the Website; (b) protect and defend the rights or property of the Company; and/or (c) act under exigent circumstances to protect the personal safety of users of the Company’s Services or the public.
TRACKING USER BEHAVIOR
By Your acknowledgment and use of cookies on our website, the Company may keep track of the websites and pages Our users visit within the Company in order to determine what Company Services are the most popular. This data is used to deliver customized content and advertising to the Company’s customers whose behavior indicates that they are interested in a particular subject area. You have the right to opt out of receipt of any other customized content and advertising from the Company.
AUTOMATICALLY COLLECTED INFORMATION
Information about Your computer hardware and software may be automatically collected by the Company. This information can include: Your IP address, browser type, domain names, access times and referring website addresses, and/or Web Cookies. This information is used for the operation of the Service, to maintain the quality of Our Services, and to provide general statistics regarding use of the Company’s Website and its Services.
HOW WE STORE YOUR PERSONAL DATA
We may store Personal Data itself or such information may be stored by third-parties to whom We have transferred it in accordance with this Privacy Policy. We take all reasonable and appropriate measures to protect the Personal Data collected via the Services from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. These measures take into account the risks involved in the processing and the nature of the Personal Data. To help maintain the security of Your data, we use administrative, physical, and technical safeguards. These include taking reasonable precautions to (a) securely and confidentially maintain your Personal Data; (b) assess and protect against threats and hazards to the security or integrity of such data; and (c) prevent unauthorized access to or use of such data. Also, except where required or allowed by law, We limit use of your Personal Data to the minimum necessary to accomplish the purposes for which that data was collected and to be used as described here. We restrict access to your Personal Data to only those who need to access it to accomplish those purposes. We use encryption to make Your online transaction with us safe and secure. We protect the privacy of Your credit card information with a high degree of care and in compliance with PCI. You, and regulatory bodies, will be alerted immediately upon any detection of a significant breach or security incident that impacts the use of Your Personal Data.
HOW TO ACCESS, UPDATE, CORRECT OR DELETE YOUR PERSONAL DATA
You can request access to your Personal Data being stored by Us. You can also ask Us to correct, update or delete any inaccurate Personal Data. You can exercise these rights by contacting us directly by email (privacy@detourinsurance.com). Your identity will be subject to verification before any deletion or modification is made to the Personal Data. If a customer initiates a data deletion request, the Company is authorized to delete or anonymize Personal Data of the requesting customer from the Services even if that means removing its availability to the underwriter through the Services. However, if You are a customer, You understand that even if the Company deletes or anonymizes your Personal Data upon your request or pursuant to this Policy, your Personal Data may still be available in the underwriter’s own databases if transmitted to the underwriter prior to the Company receiving or taking action on any deletion or anonymization activity. The Company makes reasonable efforts to keep Personal Data as accurate, complete and up-to-date as necessary to fulfill the purposes for which the information is to be used. We will consider and respond to all requests in accordance with applicable law.
HOW LONG WE RETAIN YOUR PERSONAL DATA
We may retain your Personal Data as long as required by our underwriting partners. However, we may retain Personal Data for an additional period as permitted or required under applicable laws and regulations. Even if We delete Your Personal Data, it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
YOUR CHOICES
You have several choices available when it comes to Your Personal Data:
- You may limit the Personal Data You Provide.
- If You choose not to provide any Personal Data or limit the Personal Data You provide, You may not be able to use certain Services. For instance, in order to purchase an insurance policy, Your name and email address will be required.
- You may opt out from future electronic communications.
- You may completely unsubscribe from our Services.
The Company may send you electronic communications marketing or advertising our Services. You have the right to “opt out” of receiving these electronic communications by clicking on the “Unsubscribe” link at the bottom of any such electronic communication.
Third-Party Communications
The Company is not responsible for electronic communications You may receive directly from our underwriting partners and any third-party through which You accessed or purchased our Services. In the event of receipt of such communications, please consider the Privacy Policy of such underwriting partners or third-party through which You accessed or purchased our Services.
Transactional or Responsive Communications
Certain electronic communications from the Company are responsive to Your requests. For instance, You will receive an email confirmation with Your purchase details. In addition, if You submit a claim or email Our customer support department, We will send You an email reply. Notwithstanding any unsubscribe election that You have made, You will still receive these transactional or responsive emails.
Retention
It may take up to forty-eight (48) hours for Us to process an unsubscribe request. Even after You opt out of all electronic communications, We will retain your Personal Data in accordance with this Privacy Policy, however, We will no longer use it to contact You. We are not responsible for contacting underwriters or third-parties through which You accessed or purchased Our Services. Opt-out and deletion requests pertaining to Your Personal Data transferred to such underwriters or third-parties should be directed to them in accordance with their Privacy Policies.
EXCLUSIONS
Personal Data Provided to Others
This Privacy Policy does not apply to any Personal Data that you provide to another entity through the Services or through any other means.
Third-Party Links
This Privacy Policy applies only to Our Services. The Services may contain links to other websites not operated or controlled by Us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.
PRIVACY REGULATIONS
IF YOU ARE VISITING THE SERVICES FROM OUTSIDE THE UNITED STATES, PLEASE BE AWARE THAT YOU ARE SENDING INFORMATION (INCLUDING PERSONAL DATA) TO THE UNITED STATES WHERE OUR SERVERS ARE LOCATED AND THAT INFORMATION MAY THEN BE TRANSFERRED WITHIN THE UNITED STATES OR BACK OUT OF THE UNITED STATES TO OTHER COUNTRIES OUTSIDE OF YOUR COUNTRY OF RESIDENCE, DEPENDING ON THE TYPE OF INFORMATION AND HOW IT IS STORED BY US.
General Data Protection Regulation and California Consumer Privacy Act
We are committed to complying with all applicable privacy requirements, including the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA) for the protection of personal information, as well as the principles of data security in the configuration of Our Services and use of Personal Data. If You have any questions about this Privacy Policy or how We use Your Personal Data, please contact us at privacy@detourinsurance.com Persons whose Personal Data is covered by this Privacy Policy have the right to access the Personal Data that the Company maintains about them. They may also have the right to correct, amend or delete such Personal Data if it is inaccurate or has been processed in violation of regulatory principles (except when the burden or expense of providing access, correction, amendment or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment or deletion should be sent to: privacy@detourinsurance.com If Personal Data is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third-party, the Company will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. To the extent required by privacy regulations, the Company obtains opt-in consent for certain uses and disclosures of Sensitive Data. To request to limit the use and disclosure of Your Personal Data, please submit a written request to privacy@detourinsurance.com. In certain situations, We may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. The Company remains accountable for Personal Data that it receives in the United States and subsequently transfers to a third-party in accordance with GDPR and CCPA principles. The Company commits to resolve complaints about Our collection or use of Your Personal Data. EU individuals and U.S. Citizens with inquiries or complaints regarding our Privacy Policy should first contact the Company’s Data Privacy Officer, Todd Hancock, at: Todd@detourinsurance.com
GDPR DISCLAIMER
The Company’s Services are not intended to be made available to citizens of the European Union or other European countries with data privacy regulations similar to those set forth in the General Data Protection Regulation (GDPR). Accordingly the Company makes no representations concerning the applicability of GDPR to this Privacy Policy, and all matters relating to the Company’s collection and use of Personal Data shall be governed by applicable U.S. Privacy Laws.
CHANGES TO THIS STATEMENT
The Company reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way We treat Personal Data by sending a notice to the primary email address specified in Your account, by placing a prominent notice on Our website, and/or by updating any privacy information on this page. Your continued use of the Website and/or Our Services after such modifications will constitute Your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by such modifications. The Services and Our business may change from time to time. As a result, it may be necessary for Us to make changes to this Privacy Policy. We reserve the right and sole discretion to update or modify this Privacy Policy at any time (collectively, “Modifications”). Modifications to this Privacy Policy will be posted to the Website with a change to the “Updated” date at the bottom of this Privacy Policy. In certain circumstances, the Company may, but need not, provide You with additional notice of such Modifications (as by email or with in-Service notifications). Modifications will be effective thirty (30) days following the “Updated” date or such other date as communicated in any other notice to You. Please review this Privacy Policy periodically and, particularly, before you provide any Personal Data. This Privacy Policy was updated on the date indicated below. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to You, You should cease accessing or browsing Our Website or otherwise using Our Services.
CONTACT INFORMATION
If you would like to request information about your Personal Data and how it is used by the Company, or request that Your data be deleted, please send an email to privacy@detourinsurance.com. The Company welcomes Your questions or comments regarding this Privacy Policy. If You believe that the Company has not adhered to this Privacy Policy, please contact Todd@detourinsurance.com. We will document, investigate and take corrective action where appropriate.