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. The best way to speak with us is usually in the app. If you have any questions about our handling of personal information, you can also email us at email@example.com, or write to us. We’re moving address soon – so speak to us in the app to get our up-to-date postal address!
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 offer you cover. So we’ll collect anything we need via the app, our website and any other interactions you might have with us. 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. If you haven’t bought a policy with us, you can ask us to delete some of your information. Again, the best the way to do that is usually via the app. We need to keep information in certain circumstances for the detection and prevention of fraud. We’ll retain the minimum information needed to record and prove we’ve complied with any requests, and to check the accuracy of any information we’ve provided. 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.
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.
Our conversations (including phone calls and emails) 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.
We may collect location and motion data from devices you use, and use that with other personal information when providing our services. For example to determine risk, detect unusual behaviour or help with claims processing.
If you are using our mobile app, your device has a built-in permission system for the data you choose to share with Cuvva. Like the telematics data we mentioned earlier, for example. When we want to access this data, your device will allow you to consent or deny access. You can control this in your device’s settings.
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 to you doing so.
Sharing your 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.
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 also 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. They each have their own privacy notice which we can help you find – just let us know. We may share your information with these third parties:
- underwriters of any policies you purchase
- companies Cuvva use to help us deliver our service
- any statutory body, for legal or regulatory requirements, and for fraud detection and prevention
- with another company, if we were to merge with them or were acquired by them
- anyone you have consented to provide information to, for example if you connected your Cuvva account to a third party service
If you’d like to know who your data has been shared with, let us know.
Can I access the data you hold about me?
Yes – you have a right to access the data we hold about you, or to get a copy. Usually we will provide this data in a standard portable format. If you have any trouble understanding the data, let us know and we will help. You can ask us via the app, or using our other contact details if you’d prefer. 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. To correct any inaccuracies in the information on your account, you can login to the app to update it at any time. Some information can also be updated by our support team. 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.
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.