About us 

Here in Driverly Company Limited, we will always treat your personal data with respect and design our products and services with your privacy in mind. 

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This Privacy Notice will help you understand how we collect, use and protect your personal data. 

 

Driverly Company Limited (also referred to as 'Driverly', 'we', 'us' or 'our') is the Data Controller and responsible for your personal data and is registered at 10 Churchill Way, Cardiff, CF10 2HE (Reg No: 13377155). 

 

Adam Stokes is our data protection officer and can be contacted at dpo@driverly-insurance.co.uk or at The Data Protection Officer, Driverly Company Limited, 10 Churchill Way, Cardiff, CF10 2HE. 

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Now, pour a cup of tea and get ready for a good read (or at least a thorough one). ☕️ 

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Your personal data explained 

We’re going to talk a lot about your personal data, so let’s get some basics right. 👍 

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Your personal data is the information relating to you as an individual that is linked to your name or any other way you can be identified, such as your driving license number or your insurance policy number. 

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Certain types of personal information are considered to be ‘Special Categories’ of information, due to their more sensitive nature. Sometimes we'll ask for (or obtain) special categories of information because it's relevant to your insurance policy or other services provided to you. For example, to assess risk correctly, we'll ask you about previous motoring convictions. This privacy notice highlights where we're likely to obtain special categories of information and the grounds on which we process this data. We'll only process special categories of information if they're relevant e.g. information about your health and criminal convictions. 

  

Now that we know what we’re talking about it, let’s get into it. 🤓 

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Collecting your data 

As a technology-based insurance startup, we pride ourselves on our data analytics capabilities. 👩🏼‍💻 

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We believe we can provide a much fairer price and a greater customer experience by using data and technology. To do so, we will need to process your personal data to provide you with our services. We will collect data from you, from your use of our services, and from external sources (both public and private). 

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• The personal information we collect about you may include: 

• Your contact details such as name, physical and email addresses, phone numbers; 

• Further personal details such as marital status, employment status, income information, proof of residency; 

• Government identifiers such as driving license number; 

• Your claims history; 

• Location information; 

• Machine identifiers including your IP address, IMEI and MAC address. 

• Information about how you interacted with us, our websites, and our services; 

• Information about others who will be or are included on your policy (which you should have their permission to share) 

• Information on your vehicle, some of which will be collected from external databases. Examples include road tax status and geological data for your area. 

• Data collected from External Data Sources including Regulatory bodies, Location Services providers, Motoring Agencies, Credit Data and Credit Scores, Claims Data, previous Non-Claim-Bonus data, CCJ data, Electoral Roll data and Online Behavioural Data. 

• Examples of special category data we collect may include: your medical history, criminal convictions and county court judgments 

• Your driving behaviour data (telematics data), 

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If you provide us with personal data about another individual, you acknowledge that you have permission from that individual to do so and that they understand how we will process their personal data. We would strongly encourage that any individual, whose personal data you provide to us, reads this Privacy Notice. 

  

How we collect your data 

We want to be as transparent as possible about the data we collect. 🤝 

  

• We will collect your personal data when: 

• You provide us with details for a quote 

• You purchase our products and services or those provided by our service partners 

• You interact with us or make customer inquiries including through social media 

• You register for information or other services 

• You respond to communications or surveys 

• Someone you know invites you to sign up for our services/the Driverly Club 

• We require additional information from you for validation purposes 

• We collect data about you through the use of technology such as cookies and device fingerprinting. 

  

You have the ability to accept or decline cookies from any website by modifying the settings in your browser. If you wish to restrict or block the cookies which are set by our website, you can do this through your browser settings. For information about how to manage and disable cookies, you can use the 'Help' function within your browser or please visit www.aboutcookies.org or www.allaboutcookies.org. However, please note that by deleting or disabling cookies could affect the functionality of our website and you may not be able to access certain areas or features of our site. 

  

Driving Behaviour Data (Telematics Data) 

In order to provide you with an insurance policy, we need you to download our mobile app. 📱 We will use the app in order to, among other things, capture your driving behaviour data. This information includes the date, time, latitude, longitude, speed, duration, distance, acceleration, braking, cornering, and other associated vehicle information. 

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Please note that we may team up with other companies to provide you with our telematics services. In such cases, our app normally collects information from your phone and transmits this to us and/or our suppliers after a delay. Instances, where the app may send real-time data and alerts to us, including when a collision or crash is detected. 

  

 

Using your data 

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Purposes for which we will use your personal data 

 

As you know, we love data and technology and we love data and technology to work for our customers. The data we collect from you could be used for a wide variety of reasons: 

 

• Processing your car insurance quotes; 

• Fraud detection and prevention; 

• Verifying your identity when required; 

• Undertaking market research, product development, and statistical purposes; 

• To enable us to provide you and other customers with relevant information through our marketing program; 

• Keeping you informed about promotions and new developments by email, telephone, SMS, social media, or post (dependent on your preferences); 

• For assessment and analysis to enable us to review, develop and improve the services we offer; and 

• Refining pricing models and using collected data to accurately price individuals; and 

• To make decisions about you using computerised technology to profile you, such as assessing which products might be most suitable for you. 

 

How we use your personal data  

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:  

 

• Where we need to perform the contract we are about to enter into or have entered into with you. 

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (see below). 

• Where we need to comply with a legal or regulatory obligation. 

• When we have your consent. 

• Where there is a substantial public interest. 

 

Substantial Public Interest 

In certain cases, we may ask you to provide us with information about your health and criminal convictions, in order to provide you with an insurance policy or other services, which we may also need to share with insurance underwriters. When this is necessary, we will collect this information on the basis of fulfilling a substantial public interest. 

 

 

Legitimate Interest 

Sometimes we need to use your personal data for legitimate business purposes, in order to ensure we continue to provide a great customer experience. In such instances, we will always balance our interests against yours. 

 

The processes below are considered legitimate interests: 

• Fraud detection and prevention, which may include conducting checks against external databases and your social media profiles; 

• Engaging and contacting you throughout the lifecycle of your policy to ensure you have a good experience as a Driverly customer; 

• Internally auditing our processes to maintain our high standards; 

• Some of our marketing activities; 

• Use of your quote data (whether you accepted a policy or not), data collected during the lifetime of your policy, and data collected from third parties (such as credit reference agencies), to refine our pricing and risk assessment models, to improve the accuracy of our premiums and improve the quality of our services; 

• Sharing data with selected third parties in order to add value to our products. 

  

Fraud detection and prevention 

The personal information we have collected from you may be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. 

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If false or inaccurate information is provided and fraud is identified, details may be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. 

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We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when: 

• checking details on applications for credit and credit-related or other facilities 

• managing credit and credit-related accounts or facilities 

• recovering debt 

• checking details on proposals and claims 

• checking details of job applicants and employees 

 

Consent 

 

Generally, we do not rely on consent as a legal basis for processing your personal data - other than: 

• The collection of Telematics Data from your mobile device 

• Sending third party direct marketing communications to you or  

• Sharing your data with other members of a Driverly Club. 

  

Driving Behaviour Data (Telematics Data) 

Driverly’s promise is to offer you a fair price and a great customer experience based on how you drive. We and joint controller companies we partner with will use the data captured by our app for the purposes of: 

• Calculating and charging insurance premiums based upon actual vehicle usage and compiling and generating Driving Scores. 

• Controlling your personal data for the purpose of providing you with services relating to the insurance policy. We will process your data in accordance with our responsibilities under the European Data Protection Regulation (GDPR). 

• Carrying out the activation, disconnection, servicing, updating, or testing of the app 

• General research and analysis, mapping purposes, researching and refining techniques for analyzing motor Telematics data, and the supply of traffic data. In all such circumstances, the data will be used anonymously and will not identify any individual, vehicle user, or policyholder. 

• Enabling us, joint controller companies, and any service partners, to contact you by post, electronic mail, telephone, or text messaging regarding the administration of your insurance policy and the associated services. 

• Provision of the insurance services under the policy. Data will be used for fraud prevention, detection, and investigation purposes. 

• Please note that where the Driverly App indicates a severe crash has occurred, we will try to contact the policyholder and the named driver to offer assistance. If they cannot be reached, we will try to reach anyone else named on the account. If we are unable to contact any of those persons named on the account then we will contact the emergency services with details of the vehicle, its last known location, and the names of those individuals named on the policy. 

  

 

Promotional offers from us  

We may use your Contact Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this ‘Marketing’).  

 

You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing. 

 

Third-party marketing  

We will get your express opt-in consent before we share your personal data with any company outside Driverly for marketing purposes. 

 

Surveys 

Driverly may contact you from time to time to ask you to take part in a survey, in order to enable us to review, develop and improve our services. Your survey responses, including any personal data provided, will only be used by Driverly for the purposes stated within this Privacy statement. Personal data can include (but is not restricted to) your name, age, and e-mail address. We may also collect special category personal data, depending on the survey to which you are responding. 

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How we retain your data 
 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

 
 

Presence Of Automated Decision Making 

 

We utilise automated decision-making technology about whether you are eligible for a quote or policy. This process uses information provided by you in combination with additional data, sourced from our partners (listed in the section ‘Sharing Your Data’ below) to automatically classify risk levels which may impact whether we decide to offer you a quote or policy. 

 

As per GDPR Article 15.1.H, the table below contains information about the logic involved and envisaged consequences: 

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