Our privacy notice

Here at Cuvva we take your privacy very seriously. This notice will tell you how we use your personal information.

Who we are

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 privacy@cuvva.com, or write to us at 3 Angel Square, London, EC1V 1NY.

You can also contact our Data Protection Officer (DPO) - Aphaia Ltd. They can be contacted by email at dpo@aphaia.co.uk, or you can write to them at Aphaia Ltd, Eagle House, 163 City Road, London, EC1V 1NR. It can take a few days to process requests directed to Aphaia, so you might want to send the request to us directly.

Your personal information

This means 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 need to keep your data for at least seven years. That's because you'll have purchased a regulated financial product, and because of possible future claims.

Other information we 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.

Device information

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.

Communication

Our conversations (including chats, emails and phone calls) may be recorded or monitored to provide an audit trail. We may use them to help train the Cuvva team, too.

System logs

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 and history from the DVLA, MyLicence or other relevant entities. We need this so we can offer motor insurance products to you.

Location and motion data

Before we collect any location or motion data, your device will ask for your consent. 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.

Your location can be used to determine risk, and will be recorded on your profile once you get your quote. We may need to check the location to help with claims.

We need motion data to determine accurately when you’re driving, and to work out if we can give you more accurate pricing based on driving behaviour. We’ll also use that data to determine eligibility, and to help with any claims.

We won’t use your location or motion data for anything we haven’t listed above. You can change your consent for location and motion data at any time from your device's settings. But your ability to use us will be limited if we can’t access the data we need.

Health data

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’ll 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 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.

Due to coronavirus (COVID-19) we’ve paused travel cover for a while. But as always, you can chat to us 24/7 if you have any questions.

Soft credit checks

Depending on the cover you're looking for, we might carry out a soft credit check using your details. We'll only do that when we need to, to see if we can cover you.

This means we take into account your credit score, number of judgements against you (if any), reported insurance policy history, claims data and whether you're on the electoral roll. This information won't be readily available to members of the Cuvva team. But our systems will check the data as part of the quoting process.

Soft credit checks don't leave a visible footprint on your credit file. You can see them on your own credit file, but lenders can't.

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 misuse.

As we mentioned earlier, we’re not selling travel insurance right now, though.

Publicly available information

We may use publicly available information, or information in plain view, to prevent 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.

Focus groups, feedback and reviews

We love feedback. So much so that we occasionally invite people to Cuvva HQ, or another agreed location, to find out their views. 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.

We'll occasionally email Cuvva users, when it's relevant to them, to ask for their thoughts on our service. And if we're given permission following that email, we'll get in touch over the phone too.

If you've given us feedback via our website, the app, or by chatting with us; first of all, thank you! We might email you with an update on the action we've taken following your feedback.

We don't send many emails of the kind described above. But when we do, there will always be an option to unsubscribe. We also really appreciate it when Cuvva users review us online. We may re-publish said reviews, along with your first name if that was included in your review.

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.

Cookies

As with most websites, we use cookies. You can find out more, including how to opt out in our cookie policy, which you can find on our website.

Where your information goes

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 signs a contract with Cuvva, giving assurances over the security and correct treatment of your information. Where the data is sent overseas outside the EU/EEA, the protection provided may be based on standard clauses verified by the European Commission and other data security safeguards. Or there might be an adequacy decision in place guaranteeing an equivalent degree of data protection.

You can find out more on where your information goes here.

Your data rights

Right to erasure

If you'd like us to delete your information, just let us know. Again, the best the way to do that is usually via the app. Bear in mind that if you've bought a policy with us, we may not be able to delete your account when you ask. We need to keep your data for at least 7 years from when your most recent policy expired. That's in case of any future claims against you, any disputes, or anything else meaning we need to show records of your cover.

In other cases, where we delete your account, we'll archive some information 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.

To do that, we'll retain the minimum information needed in the circumstances. That can include your conversation history, email address, name, date of birth, any legal terms you've agreed to or copies of quotes we've issued. That archived data won't be accessed unless it's needed for the above reasons, and it will be deleted after 7 years.

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.

Your obligations

If you have purchased a policy from us, it will include rules about information you must provide.

Changes

We keep our privacy notice under regular review. 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 Information Commissioner’s Office.

v1.11 (2020-06-26)

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Cuvva is authorised and regulated by the UK Financial Conduct Authority. (#690273)