Privacy Notice - Zego customers

Who is this Privacy Notice for?

This Privacy Notice applies to Zego customers policyholders and/or named drivers on a Zego Insurance Policy and potential customers (e.g. if you contact Zego for a quote).

What data do we collect and how do we collect it?

When you sign up for personal insurance products through Zego directly, become insured through one of our fleet partners or brokers or you contact us about a claim, the information we usually get from you and/or our partners includes:

• IInformation such as your name, date of birth, gender.
• Contact details like your email address, phone number, home address.
• Identity documents such as your driving licence, ID card, private hire documents.
• Payment details including your credit/debit card details and bank account details.
• Details about your vehicle like your registration number,specifications, modifications, details of other insurance you have, MOT.
• Work provider information - who you work for or with.
• Claims information including: details about claims you have had in the past on other insurance policies; all claim(s) you have reported to us; any current active/open claims; details of any claims  involving you made by a third party.
• Details of any past and current motoring convictions.

We use Automated Decision Making (ADM) based on the information you provide to assess whether you meet the underwriting criteria for the insurance product you have selected. ADM and profiling will also be used to assess your information in relation to your risk profile as a driver.

We also perform checks to make sure we can insure you. Information we get from those checks includes:

• Past claims - more specific details on your past claims such as which insurer you claimed under and the policy that was affected.
• Motoring convictions - more specific details on your past convictions such as outcome and amounts fined.
• Identity validation - checking against the information you gave us to make sure it is all correct.
• Fraud checks - checks against national fraud detection databases.

Then when you are using our services we may gather:

• Telematics information - if you have an approved telematics device installed (for example, the Sense app) we collect on your driving behaviour, vehicle, GPS location, and phone use. We analyse this data so that we can create fairer and more accurate pricing for our products. In certain cases this involves creating risk profiles of customers. For more information on the data collected via the Zego Sense app, please read the Sense app privacy notice which is available on the app.
• The shifts you work - we get the shifts you work from your work provider’s app when you are using it. It is all integrated so that you get insurance for when you are working and not when you don’t need it.
• Video/audio recordings while driving - where you have a video camera installed, we may request that information from you, for example, if there is an accident leading to a claim on your policy.
• Enriched data - this gives us a better understanding of your risk as a driver allowing us to create fairer pricing in our insurance products. This enables Zego to determine potential insurance risk scores in more granular detail and in turn, this will allow Zego to build fairer pricing for our insurance products in the future. Special categories and criminal offence data data may be used where relevant.
• When you access our claims service, we may use tools to help us assess and protect against fraud.

Is it legal?

We collect all of this information so that we can provide you with insurance. Our reasons (lawful basis) for collecting and using this data can include:

• Performance of contract - Most of the things we do and the data we collect is so we can provide you with your insurance, e.g to create your policy, provide you with cover or make sure we can cover you. This also includes processing and managing a claim on your policy. Our use of ADM also takes place for the performance of our contract with you.
• Legal obligation - Sometimes the law tells us what we need to do with your data, e.g. when we run checks on your data we are doing it to meet regulatory and legal requirements, including for the prevention and detection of fraud and crime. We are also legally required to keep your data for certain amounts of time.
• Consent - Sometimes we may ask for your consent to process your data. In these cases, it is your decision whether or not we process your data in that way and you can change your mind at any time. An example of this will be for marketing - you can choose to receive it or not, and you can change this at any time from your account.
• Legitimate interests - We may need to process your data for the legitimate interests of Zego’s business, for example:
  - To continue to improve the products and services we offer, including contacting you for feedback about Zego’s products and services
  - The prevention and detection of fraud
  - To recover funds owed to Zego

Does anybody else get your data and where is it stored?

We are the data controller for your information. We do share your information with other organisations and we also use other organisations to process some of your data. At all times, privacy remains paramount and we endeavour to minimise the data shared.

We share your information with the following:

• Insurers, intermediaries and reinsurers to administrate your insurance.
• Third parties and services we use to help us process claims - those include claims processors, repair networks, third-party insurers, consultants to help assess the claims, and professional services we use to assess claims involving injuries.
• Telematics services providers we have partnered with, to obtain and use data related to your driving behaviour in connection with your insurance contract with us.
• Financial service providers to arrange your credit.
• Government, regulatory and legal bodies including the Financial Ombudsman Service and the Financial Conduct Authority (FCA) to make sure we meet our legal requirements.
• Identity, fraud detection agencies and legal check providers to perform our legal checks and checks to detect and prevent fraud.
• Debt collections agencies for the recovery of funds due to Zego.
• Enhanced data providers to better understand potential insurance risk and to improve our products and to provide you with a more tailored price for your insurance.
• Payment services to process your payments and run finance reports. We may also use your bank or credit provider to process your payments and refunds for example.
• Work Providers to verify your identity, confirm that you have the correct insurance in place and analyse data to improve our products.
• Advertising measurement services Zego will share limited data about you with our online ad service providers to optimise the way that we target our ads.
• People who contact us on your behalf, such as friends or family if you have given your consent. This could also include lawyers, criminal offices or others who contact us legally on your behalf.
• Service providers, for example for customer service, for our data storage, for our internal correspondence, and other providers who help us to run our day-to-day business.
• Other insurance brokers - if we are unable to get an insurance quote for you we may share your details with other trusted insurance brokers we work with in order to help you get the cover you need.

Most of our services are in the EU. We have safeguards in place including contractual clauses to ensure where the data is processed outside of the EU the company meets the standards as required by the EU and UK law.

The Motor Insurers’ Bureau (MIB)

In the UK, we work in partnership with the Motor Insurers’ Bureau (MIB) and associated not-for-profit companies who provide several services on behalf of the insurance industry. At every stage of your insurance journey, the MIB will be processing your personal information and more details about this can be found via their website at mib.org.uk.

Set out below are brief details of the sorts of activity the MIB undertake:

• Checking your driving licence number against the DVLA driver database to obtain driving licence data (including driving conviction data) to help calculate your insurance quote and prevent fraud.
• Checking your ‘No Claims Bonus’ entitlement and claims history.
• Prevent, detect and investigate fraud and other crime, including, by carrying out fraud checks.
• Maintaining databases of:
  - Insured vehicles (Motor Insurance Database)
  - Vehicles which are stolen or not legally permitted on the road (MIAFTR)
  - Motor, personal injury and home claims (CUE)
  - Employers’ Liability Insurance Policies (Employers’ Liability Database)
• Managing insurance claims relating to untraced and uninsured drivers in the UK and abroad.
• Working with law enforcement to prevent uninsured vehicles being used on the roads.
• Supporting insurance claims processes.

Personal information of others

If you provide us with someone else’s information for the purposes of either obtaining a quote or purchasing a policy with them as a named driver, please ensure that:

• You have informed them how we will be using their personal information.
• They know how to find our Privacy Notice and that they have read it.

If you give us information about another person (for example a family member or a client), it is your responsibility to ensure and confirm that:

• You have told the individual who Zego is and how we use personal information (as set out in this Privacy Notice).
• You have permission from this individual to provide their personal information (including any sensitive personal data) to us and for us to process it, as set out in this Privacy Notice.

How long do we keep it for?

Zego has a retention policy which sets out how long we will keep your information for, including while you are a customer with us and after that for as long as the law requires or allows us to do so. We keep most of the data associated with your policy, telematics data and claims for 7 years. We might need to keep some data regarding claims for longer in accordance with legal requirements.

We keep your personal information for as long as reasonably necessary to fulfil the purposes set out in this Privacy Notice and to comply with our legal and regulatory obligations. Where we can, we will minimise personal data or de-personalise it so we can use it for statistical or analytical purposes.

Marketing

If you have previously purchased insurance or enquired about one of our products we may contact you about similar products in the future.

We may also provide you with new product information and offers for Zego’s products and services via marketing tailored to you, including by direct marketing and by phone, e-mail, text, social networking channels and post for example. This may be direct from Zego or sometimes via a third party.

We will also use information we hold about you to help us identify, tailor and package our products and services, determine pricing and offer discounts that may be of interest to you.

We will not use sensitive personal details (such as information relating to your health or any criminal issues) in order to provide you with marketing, discounts or pricing unless you have given your explicit consent to allow us to use this information for these purposes.

We want you to have control over how we use your information to make offers and how we communicate these to you. You will always have the option to say no and to opt-out of receiving marketing from us. You can change your marketing preferences and opt-out at any time by contacting us at [email protected] or 020 3308 9800 or by using our ‘exercise your rights’ button below.

Feedback

As part of our commitment to understanding our customers better we may also ask you to participate in surveys from time to time. It is entirely voluntary whether you wish to take part.

If you do choose to engage in these surveys, we may ask you for your permission to include your story or testimonials in Zego communications. We will keep this data for 6 months.

We rely on legitimate interests to process your personal data in this way and will be transparent with you about how and why we are using it.

What are your rights?

Below are your rights in no nonsense language but just in case you want to know, their official data protection name will be in bold.

• The right to know how we collect and use your personal data and what happens with your data. We do this through our privacy notice. “The right to be informed”
• The right to access and receive a copy of your personal data. You can ask us to give you the data we hold about you. We must send you your data within one month, although we can extend the time by up to 2 more months if your request is complex. “The right of access”
• The right to change your personal data if it is incorrect. Do you think the information we hold on you is wrong or perhaps it needs updating? We will do everything we can to make sure our information about you is accurate but if you can show us it's not, just ask us to change it and we will if we can. “The right to rectification”
• The right to ask us to delete your personal data. You can ask us to delete your data in some circumstances and if we can delete it, we will. “The right to erasure (right to be forgotten)”
• The right to stop us doing some things with your personal data. This means you can ask us to limit or restrict the way we use your personal data, and if we can stop using your data in that way, then we will. “The right to restriction”
• The right to have a copy of your personal data so you can use it elsewhere. If you want the data you gave us so that you can give it to someone else, we can give it to you. “The right to data portability”
• The right to say no. You can tell us when you do not want us to use your personal data or you object to us using your data. Once you have told us to stop using your data, we will stop using it if we can. “The right to object”
• The right to ask us to use people instead of computers to make our decisions. We use computers and ADM to help us make decisions, for example, to make sure you meet our underwriting criteria, to make sure your data is accurate, and for verification or identity checking. If you are unhappy with a decision made this way or you think the decision is incorrect or unfair, you can ask us to have a human being review it. “Rights related to automated individual decision-making including profiling”
• You have the right to withdraw your consent at any time. We ask for your consent to contact you about things that are not directly to do with your current contract with us. For marketing, for offers and maybe in the future for new products or services for example. When we ask you consent you can at any time change your mind.

How to exercise your rights

• To delete your data or make changes to your marketing preferences, please contact us via Live Chat by signing into your account at zego.com/my-zego and starting a chat with our team. You can also contact us on 020 3308 9800 or by emailing the team on [email protected]
• To make changes to your account please use Zego Delivery or Zego Sense App.
• To request a copy of your data, to object to processing or to make a request about automated decision making, please use the form below to raise your request through our Privacy Portal.

Who can you contact?

If you would like to contact Zego about your personal data, you can email the Data Protection team at [email protected] or write to them at the address below.

In the UK:
Zego
7th Floor Exchange House
12 Primrose Street, London
EC2A 2BQ

In the Republic of Ireland:
Zego B.V.
38 Upper Mount Street
Dublin 2

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your personal information:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline - 0303 123 1113
https://ico.org.uk/make-a-complaint/data-protection-complaints/

Changes to this Privacy Notice

We may amend this Privacy Notice for example, to keep it up to date or to comply with legal requirements, so we ask that you take a look at it again from time to time to check for any changes.