Privacy Notice for Fleet Insurance Policies

Last Updated: 20 October 2022

About This Notice

This Privacy Notice sets out how Humn.ai (Humn, we, our, us) will process personal data in relation to our fleet insurance products and services, including Rideshur. This includes personal data relating to fleet managers and drivers of fleet vehicles.

Information for Drivers

There may be instances where we do not have a direct contractual relationship with you. Our contract may be with a third party, for example, a drivers employer, the insurer of a vehicle, the owner of the drivers vehicle or the broker placing the vehicle insurance policy with the insurer (The Contracting Entity).

The Contracting Entity will also be a Data Controller under data protection legislation.
It is very important that you read this Privacy Notice in conjunction with that offered by the relevant Contracting Entity in order to understand how your data is processed and the legal basis for onward transfer to us. This Privacy Notice only covers the processing performed by Humn and not those processes performed by The Contracting Entity.
If you are reading this having received an e-mail or a notification regarding Driver ID we have been provided with your details by The Contracting Entity in order to provide them with a Contract for Insurance. As part of this service we require to know who is driving which vehicle covered by that policy. We do so under the basis of legitimate interest. If you have any questions in relation to this please contact the Data Protection and Privacy Office on the details provided below.

How We Receive This Information

Where you provide personal data about other third-party individuals, such as drivers of vehicles, where appropriate, you should direct these individuals to this Notice to ensure they understand how we collect and use their personal data.

We collect personal information from a number of different sources. These include:
  • Directly from you in person, by telephone, email or via our website and app;
  • From third parties involved in the contractual chain of vehicle licensing - in the case of drivers for example this may be The Contracting Entity;
  • From other third parties involved in your insurance policy or claim such as another insurer, claimants, defendants, or witnesses;
  • From other third parties who provide a service in relation to your insurance policy or claim such as claims service providers, loss adjusters, claims handlers, medical experts, healthcare providers, emergency assistance personnel, legal counsel, and other professional service providers;
  • From publicly available sources such as internet search engines and social media sites;
  • From data contributors such as software houses and intermediaries;
  • From risk analysis, fraud prevention, credit reference agencies and identity verification companies;
  • From insurance industry fraud prevention and detection databases and sanctions screening tools;
  • From providers of demographic and vehicle data;
  • From call recordings when interacting with us;
  • From our website and app including through the use of cookies and web analytics. Please see our Cookies Policy for further information;
  • From third parties who we buy marketing lists from;
  • From third parties who provide us with details of companies who have expressed an interest in hearing about our products and services such as when we receive data through introducer agreements;
  • From third party telematics providers and OEM’s;
  • From local authorities;
  • From brokers and insurance intermediaries;
  • From other insurers;
  • From third parties in connection with any acquisition or merger of a business by us.

The Personal Information We Collect

We collect a range of different personal information in order to provide or offer our services to you. The information that we process will depend upon our relationship with you as set out above in the section “About this Notice”.
If you are providing information to us regarding a third party, such as when The Contracting Entity shares driver data with us, you agree to inform the individual of who we are, that we are a third-party Data Controller processing their information and give them an opportunity to view this Privacy Notice before submitting their data to us.

Basic Categories Data

  • Biographical information such as your name, title, date of birth, age, occupation and years resident in the United Kingdom;
  • Personal contact information such as home address, personal email address, telephone number, social media information;
  • Professional contact information such as the name of your employer, work address, work e-mail and telephone number;
  • Financial information such as bank details, payment details and information obtained as a result of credit checks;
  • Online and transactional information such as details of your IP address and interactions that you have with our websites and digital platforms. Please see our Cookies Policy for more information;
  • Telematics data such as GPS location, time and date, direction of travel, speed, accelerometer data, safety events as processed and detected by the telematics service provider, CAN bus data;
  • Vehicle data such as registration, VIN, make and model;
  • Driver licence related information such as related data such as type of licence held, licence date and licence number;
  • Dashcam data such as images captured by the dashcam device(s);
  • Diagnostic data such as vehicle fault codes, better health status etc;
  • Your opinions and preferences in relation to your working conditions.
The provision of your telematics data allows us to track your vehicle in real-time, map and analyse your trips in order to calculate your risk score.

Special Categories Data

Special Categories data that we process include:
  • Medical information such as your current or former physical or mental health and historic confirmed personal claims information;
  • Information relating to criminal convictions and motoring offences such as endorsements on your licence;
  • Your raw data and reports from psychometric questionnaires.

What We Use Your Data For

Whenever we process personal data we must have a legal basis in order to do so. Please refer to the sections below to find out more about our processing activities.

Contract

  • In order to process any application you make for policy cover;
  • Providing you with policy cover, including underwriting and claims handling;
  • Administering and managing your motor insurance policy;
  • Providing any additional services to you as agreed such as top up products. For example, policy checks for fleets;
  • Providing you with risk management insights and driver behaviour data;
  • Managing any disputes or complaints in relation to our contractual relationship with one another.

Legal or Regulatory Obligation

  • To fulfil our obligations as an entity regulated by the Financial Conduct Authority (FCA) and The Financial Ombudsman Service;
  • Contacting the insured/ policyholder during the renewals process;
  • To fulfil your data rights under data privacy laws, handle complaints about data privacy or our insurance products and services and to comply with other legal requirements.
In this respect, please note that we may have to process your data to comply with other legal obligations such as requests from law enforcement agencies or other international and national governmental and regulatory bodies. This will be covered more fully in the section below regarding “Who we share your data with”.

Legitimate Interest

  • In furtherance of our commercial activities such as to maintain and manage our business operations, management reporting information and internal process requirements;
  • To develop and improve our products and services;
  • To communicate with you regarding additional product offerings, awareness campaigns, research projects and surveys you may wish to participate in and to facilitate marketing campaigns and events;
  • To carry out business to business to customer awareness campaigns such as driver safety;
  • To monitor your use of our platform and subsequently provide you with any help or support in relation to our products and services;
  • To send out promotional materials and/or gifts;
  • To offer additional services to drivers such as our incentive programme and driver coaching;
  • For the purposes of reinsuring and the insurance renewal process.
  • In order to facilitate Driver ID so that we accurately identify the driver for any given trip in order to provide our products and services.
  • To communicate with you regarding any queries you raise via the website.
  • To send you (the driver) reports about your driving and training materials.
  • To send reports about your driving to your employer.
Where we rely on this lawful basis, we conduct a balancing exercise to ensure that our interests are proportionate and do not override your rights and interests as a data subject.  In some instances, you also have the right to object to this kind of use. If you wish to object to this type of processing please contact the Data Protection and Privacy Office details of which can be found below.

Establishment, Exercise or Defence of Legal Claims.

  • We may process your personal information for the establishment, exercise, or defence of legal claims or if we proceed with a claim against you.