Our privacy notice

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

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 data, 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 Cuvva Limited, 6th Floor, Senna Building, Gorsuch Place, London, E2 8JF.

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 data

This means information which identifies you, or can be used with readily available information to identify you. We need personal data 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.

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 telematics data

Before we collect any location or telematics 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.

We may use motion data to see if we can cover you, to determine accurately when you're driving, and to work out your pricing based on driving behaviour. We may also use that data 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.

Quotes, pricing and claims data

We may collect data on quotes, pricing and claims to help us improve our pricing, processes and those of the relevant insurer, to help with risk modelling, and to help with the detection and prevention of fraud.

By continuing, you acknowledge that quotes, pricing and claims data belongs to us (to the extent that it doesn't include your personal data) and that we are entitled to retain data relating to your quotes, policies, telematics, claims and other information as long as is necessary and thereafter on an anonymised basis (see "How long we keep your information for" below)."

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.

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.

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.

We may share our data on your quotes, price, location, telematics, claims and other information with our underwriters and third party providers (such as telematics service providers). Where necessary, this will include your personal data (such as where personal data is needed to arrange, administer and underwrite your policy). Where practicable, we will anonymise your personal data when doing so.

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.

How long we keep your information for

We'll keep your data only for as long as there's a need to. This includes retaining your personal data for as long as is necessary to:

  • respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

If you're a customer and you've bought a Cuvva policy, we need to keep your data for at least seven years from when your most recent policy expired, or for at least seven years from when any claim made under your policy was finally decided or settled, whichever is later.

When it's no longer necessary to keep your personal data, we'll delete or anonymise it. After this period, we're entitled to retain data relating to quotes, policies, telematics, claims and other information on an anonymised basis, which shall belong to us to the extent it doesn't include your personal data.

If you've created a Cuvva account but you haven't bought a Cuvva policy, or if it's been more than seven years since your most recent Cuvva policy expired or finally decided or settled claim (whichever is later), we may be able to delete your account upon your request. There's more information on that below.

If you've applied for a job at Cuvva and you weren't successful this time around, our systems will automatically delete your data after 12 months.

Your data rights

Right to erasure

If you'd like us to delete your information, just let us know. Again, the best 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 seven 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.

There may be other reasons why we won't be able to delete your account even where you haven't bought a policy; for example any disputes, or for the detection and prevention of fraud.

In other cases and wherever we can, we will delete your account upon your request. By doing so, your personal data will be removed from our live systems. Your data will still exist in the electronic ether, but it will have been put beyond use. This means that your data would be far more difficult for us to access, and we will have no intention to use or access it again. There may be rare cases where we need to retrieve such archived information, for example if we're required to by a court order.

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 parts of your account. Some information can only be updated by our support team - so please speak to us if you'd like any help. Changing information on your account could impact your pricing, and it could mean that we're no longer able to offer you one or more of our products.

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, 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

v1.13 (2021-08-17)

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