PRIVACY POLICY (our site) is a website owned and operated by Twilo Investments Ltd (“we”, “us” or “our”) of 71-75 Shelton Street, London, England, WC2H 9JQ.

The terms “you,” “your,” and “yours” refer to the individuals using our site and purchasing insurance from us. We are committed to safeguarding the privacy of our site visitors; this policy sets out how we will carefully treat your personal information.

From time to time our site uses cookies. By using our site, you consent to our use of cookies in accordance with the terms of this policy and you consent to the data practices prescribed in this policy. We may periodically make changes to this Privacy Policy that we will include on this page. Any changes to this Privacy Policy will be communicated to customers by email or by announcement on our site.

Before using our site, requesting a quote, or obtaining any insurance policies you must agree to our Terms and Conditions found here.


We may collect, store and use the following kinds of personal information:

  • information about your computer and about your visits to and use of our site (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation);
  • information relating to any transactions carried out between you and us on or in relation to our site including identification and contact information, personal data relating to insurance transactions (including but not limited to personal data relating to quotes, insurance policies and claims), payment card and bank account details, credit reference and scoring information). Due to the nature of our products this may include sensitive personal information about your health and other information required by the underwriter Acasta European Insurance Company Limited, Registered in Gibraltar with a company number: 96218 (“Acasta”) or any other insurance provider;
  • information that you provide to us for the purpose of registering with us;
  • information that you provide to us for the purpose of subscribing to our site services, email notifications and/or newsletters;
  • any other information that you choose to send to us.


Personal information submitted to us via our site will be used for the purposes specified in this privacy policy or in relevant parts of our site.

We may use your personal information (and may pass your personal information to Acasta and Acasta’s designated third parties to enable them) to:

  • administer our site;
  • improve your browsing experience by personalising our site;
  • enable your use of the services available on our site;
  • insurance administration, e.g. communications, claims processing and payment;
  • decision-making on the provision of insurance cover and where applicable payment plan eligibility;
  • assistance and advice on medical and travel matters;
  • management and audit of our business operations;
  • send you general (non-marketing) commercial communications;
  • send you email notifications which you have specifically requested;
  • send to you our newsletter and other marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
  • provide third parties with statistical information about our users – but this information will not be used to identify any individual user;
  • provide customers with reports, summaries, data and information;
  • deal with enquiries and complaints made by or about you relating to our site;
  • invite you to review our site using a trusted third-party service;
  • prevention, detection and investigation of crime, e.g. fraud and money laundering;
  • establishment and defence of our legal rights; and
  • legal and regulatory compliance, including compliance with laws outside the United Kingdom.

Where you submit personal information for publication on our site, we will publish and otherwise use that information in accordance with the licence you grant to us.

We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.


You agree that we have the right to share your personal information with:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
  • Selected third parties including:
    • Acasta, business partners, suppliers and sub-contractors for the performance of any contract we or they enter into with them or you;
    • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
    • analytics and search engine providers that assist us in the improvement and optimisation of our site;
    • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Twilo Investments or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions [(insert link)] and other agreements; or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

All our site financial transactions are handled through our payment service provider Stripe. Generally you will enter the information directly on the Stripe system but we may share information with a payment service provider only to the extent necessary for the purposes of processing payments you make via our site and dealing with queries relating to such payments.

You can view the privacy policy for Stripe) here:


Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this privacy policy.

Information which you provide may be transferred to countries which do not have data protection laws equivalent to those in force in the European Economic Area.

In addition, personal information that you submit for publication on our site or via its associated third party services (for example social media) will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

You expressly agree to such transfers of personal information.


We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure (password- and firewall- protected) servers.

Where applicable, you are responsible for keeping your password and/or user details confidential. We will not ask you for your password (except when you log into our site).


You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to:

  • the payment of a fee (currently fixed at £10); and
  • the supply of appropriate evidence of your identity

We may withhold such personal information to the extent permitted by law.

You may instruct us not to process your personal information for marketing purposes, by sending an email to us. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.


Our site contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.


A cookie consists of a piece of text sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

  • Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site or make a purchase.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose
[We also use Google Analytics to analyse the use of our site. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our site is used to create reports about the use of our site. Google will store this information. Google’s privacy policy is available at: ].

From time to time we will use other trusted third party services to enable the service which may use cookies for other reasons; these may include, but are not restricted to, YouTube (our online video service provider), Twitter (social media service provider) and Facebook (social media service  provider). We are not responsible for any content or cookies served by these third parties. If you wish to understand how these third party services treat your personal data, you should refer to the individual Privacy Policy on their website.

Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, and will mean that you cannot take advantage of some of our website’s features and may not be able to participate in some projects.

[When we send out our newsletters, we’ll sometimes track who opened the emails and who clicked the links. We do that to measure our newsletter’s performance and to improve our features for specific groups of customers. To do this, we use mail providers who include single pixel gifs, also called web beacons, in emails sent from us or on our behalf. Web beacons allow us or our mail providers to collect information about when you open the email, your IP address, your browser or email client type, and other similar details, which we use to improve our services].

You can see more details about the cookies we use in the appendix below.


Please let us know if the personal information which we hold about you needs to be corrected or updated.


If you have any questions about this privacy policy or our treatment of your personal information, please write to us by email to or by post to Twilo Investments, 71-75 Shelton Street, London, England, WC2H 9JQ.


The data controller responsible in respect of the information collected on this website is Twilo Investments Ltd, our data protection registration number is [No].

Effective date:  XX May 2017



Cookie NamePurpose
e.g. stripe.csrfA random token to prevent cross site request forgery