Here at Cuvva we take your privacy very seriously. This notice will tell you how we use your personal information.
Who are you?
We're Cuvva Limited (Cuvva, we, our, us). We're authorised and regulated by the Financial Conduct Authority (FCA) under number 690273. And we're registered with the Information Commissioner's Office under number ZA056769.
If you have any questions about our handling of personal information, the best way to speak with us is usually in the app. Otherwise, you can email us at email@example.com, or write to us at 12 Mallow Street, London, EC1Y 8RQ.
You can also contact our Data Protection Officer (DPO) - Aphaia Ltd. They can be contacted by email at firstname.lastname@example.org, or you can write to them at Aphaia Ltd, Studio 5, 155 Commercial Street, London E1 6BJ. It can take a few days to process requests directed to Aphaia, so you might want to send the request to us directly.
What's my personal information?
That's information which identifies you, or can be used with readily available information to identify you. We need personal information to see if we can cover you, to calculate the premium, and to help with any claims. So we'll collect anything we need via the app, our website and any other interactions you might have with us. You can find more detail on the information we ask for here.
We'll keep your personal information only for as long as we need to. If you've bought a policy with us, we're required by the FCA to keep your data for at least seven years. That's because you'll have purchased a regulated financial product.
What other information do you collect?
We collect other information via the app, our website and other interactions you might have with us - to deliver the best service we can. All information we collect can be used to help us improve our service, for providing better customer support, and for calculating prices for your quotes. Calculating pricing requires automated decision-making and profiling.
We may record the type of device or browser you use, including the model, operating system, software, language, so we can provide better support - e.g. if you're having problems with the app.
We use device advertising identifiers to help determine how users find us. For example, once you download the app, we may be able to know which of our ads you saw beforehand (like a Facebook ad, or whether you found us via a Google search). This helps us direct resources at the most effective advertising channels, which in turn helps us keep customer costs to a minimum. You can control our ability to use device advertising identifiers in your device's settings.
Our conversations (including chats, emails and phone calls) may be recorded or monitored to provide an audit trail.
Access information may be gathered when you use our services, including device IP addresses, access dates and times, system activity including app malfunction or screens viewed, and the third-party sites or services you were using before using our service.
Driving licence data
Once you've entered your driving licence details and agreed to the Fair Obtaining Notice, we may collect information about your driving licence from the DVLA or relevant authorities. We need this so we can offer motor insurance products to you.
Location and telematics data
Before we collect any location or telematics data, your device will ask whether you'll allow location services. Your device should give you the option to allow location services always, while using the app, or never.
We need your location to offer you a quote. It helps us prevent misuse, and lets us know you're purchasing from the right place - bearing in mind you can only purchase our products while you're in the UK. If you choose to never allow location services, your ability to use us will be limited.
If you choose to allow location services while using the app, then we'll use your location to help generate a quote upon your request. Your location can be used to determine risk, and will be recorded on your profile once the quote is provided to you. We may need to check the location to help with claims processing.
If you choose to always allow location services, we'll use location data in the same way as if you choose to allow it while using the app - but with the addition of using motion data, from devices you use, if you're using our motor insurance products. This can be used to record journeys while your policy is active, to help prevent misuse, or help with claims processing.
No matter which option you choose for location services, you can change this at any time in your device's settings.
We'll process this if you use our travel insurance products. This will be done when you answer medical questions in the app, or if you'd like to chat with us about your health or someone else's.
We only ask you the questions we need to, in order to arrange travel insurance for you and any companions. Your answers will be used to determine risk, help process claims, and prevent against misuse. Your answers will be shared with the underwriter of your policy for those same reasons, and will be stored in relation to any claims. You can read the questions we ask here.
Any information relating to your health is given by you, with your express consent, so we can use it for the above reasons only.
Similarly, any information relating to someone else's health is given by you, with express consent given by them, or someone with parental responsibility for them, so we can use it for the above reasons only.
Travel destinations and dates
We'll ask for this information to arrange any travel insurance products. We need to know those details, and share them with the underwriter; to determine risk, help process claims, and to prevent against misuse.
Publicly available information
We may use publicly available information, or information in plain view, to prevent against misuse. We may take appropriate action based on any such information we come across. For example, if we see information which shows a vehicle driving dangerously, we may decide to ban that vehicle and/or the driver. We don't systematically browse publicly available information to compare it with our user information, but we may use targeted approaches and tools, to the extent they're proportionate and non-discriminatory.
Occasionally we'll invite people to Cuvva HQ, or another agreed location, to canvass their views and carry out branding exercises. This will include the use of personal data which will be made clear to the people involved beforehand. Usually name, contact details and sometimes a video of the exercise. We'll only do so with the explicit consent of those involved. If consent is withdrawn, we may continue to process the data in anonymised form.
Information relating to children
Children (individuals under 18) have the same rights as adults over their personal data.
We'll process information relating to children in the above ways, for the performance of an insurance contract, or for our legitimate interests in providing the best service we can.
If you're under 18 and would like to use our service, remember you can ask us any questions in the app.
Third party services
If you choose to connect your Cuvva account with a third party, like Facebook for example, we may ask for access to information held by the third party. They will allow you to consent or deny access, and you can control this via their services.
Be aware of the privacy policies of any third party service you use, even if you have reached that service through a link from Cuvva.
Other people's consent
If you choose to share someone's information with us, it's your responsibility to ensure they consent, or someone with parental responsibility for them consents, to you doing so.
Sharing data with other people
If you use Cuvva with a car which belongs to, or is registered to, someone else, we may share your policy information with them - including the legal documents.
If you arrange travel insurance for any companions, their policy documents will be emailed to them directly, to the email address(es) you provide us with. So it's important you provide the correct email address each time.
Where does my information go?
The data we collect from you may be transferred to and stored somewhere outside the European Economic Area ("EEA"). It may be processed by staff outside the EEA who work for us or one of our suppliers.
The parties we send your information to are obliged to comply with data protection laws, regulations and standards. Each of them is either; EU/EEA based, EU/US Privacy Shield compliant, or is based in a country recognised by the European Commission as having adequate protection. They also each have their own privacy notice. If you'd like help finding them - just let us know.
You can find out more on where your information goes here.
What are my data rights?
Right to erasure
If you haven't bought a policy with us, you can ask us to delete your information. Again, the best the way to do that is usually via the app.
We need to keep some information in certain circumstances for the detection and prevention of fraud, to check the accuracy of any information we've provided (like quotes for example) or in case of any future disputes.
In those cases, we'll retain the minimum information needed in the circumstances. To do this, we keep your conversation history, name, date of birth, any legal terms you've agreed to and a copy of the quotes we've issued.
Right to object
You have the right to object to the processing of your data in certain circumstances. For example, you have the right to stop your data being used for direct marketing. We don't send many marketing emails. But if you've opted in to our updates and change your mind - you can unsubscribe at any time.
Right to portability
You have a right to get a copy of the personal data we hold about you. We'll provide your data in a standard portable format. If you have any trouble understanding the data, let us know and we'll help. The best way to ask is usually via the app.
We won't usually charge a fee for providing that information, but we may do in certain circumstances. For example, if you make repetitive requests for information, we may charge a small fee or refuse your request.
Right to rectification
You can login to the app to correct any inaccuracies in the information on your account. Some information can also be updated by our support team - so please speak to us if you'd like any help.
Right to restriction
You have a right to restrict the processing of your personal data in certain circumstances. This means you can limit the way we use your data.
This is an alternative to requesting the erasure of your data. For example, we could securely and temporarily store your data in another system if you contest its accuracy and we need to verify it.
If you have purchased a policy from us, it will include rules about information you must provide.
We keep our privacy notice under regular review, and we'll tell you when we make material updates - by email or by notifying you in the app or our website. We regularly make small changes, so we suggest that you check the latest notice now and then.
Questions, comments or concerns
Please get in touch if you need to talk to us about anything, and we'll do our best to help.
If you've made a complaint and are still unhappy, you can speak with the ICO: https://ico.org.uk/concerns