Privacy Notice for Single Commercial Vehicle Policies
Last Updated: 27 January 2023
About This Notice
This Privacy Notice sets out how Humn.ai (Humn, we, our, us) will process personal data in relation to single commercial vehicle products and services. This includes personal data relating to the policyholder and any drivers on the policy.
For policies with Kinetiq Underwriting Ltd (The Contracting Entity), Humn process your data if you have selected their traditional policy or if you have a telematics device fitted as part of your policy. Humn and The ContractingEntity are Joint Controllers for the purpose of communicating with you about your policy and to provide policy related information, including information about your telematics device. For all other purposes and processing of your information, Humn and The Contracting Entity are Independent Controllers.
It is very important that you read this Privacy Notice in conjunction with that offered by The Contracting Entity in order to understand how your data is processed and the legal basis for data sharing between both parties. This Privacy Notice only covers the processing performed by Humn and not those processes performed by The Contracting Entity. If you have any questions in relation to this please contact the Data Protection and Privacy Office on the details provided below.
For policies with Kinetiq Underwriting Ltd (The Contracting Entity), Humn process your data if you have selected their traditional policy or if you have a telematics device fitted as part of your policy. Humn and The ContractingEntity are Joint Controllers for the purpose of communicating with you about your policy and to provide policy related information, including information about your telematics device. For all other purposes and processing of your information, Humn and The Contracting Entity are Independent Controllers.
It is very important that you read this Privacy Notice in conjunction with that offered by The Contracting Entity in order to understand how your data is processed and the legal basis for data sharing between both parties. This Privacy Notice only covers the processing performed by Humn and not those processes performed by The Contracting Entity. 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:
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 your insurance policy - for example The Contracting Entity;
- 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 party telematics providers;
- 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 our services to you.
Basic Categories Data
- Biographical information such as your name, title;
- Personal contact information such as home address, personal email address; telephone number;
- 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.
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.
Legal or Regulatory Obligation
- To fulfil our obligations as an entity regulated by the Financial Conduct Authority (FCA) and The Financial Ombudsman Service;
- 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
- Facilitate the provision and maintenance of the telematics device and receive information captured about the status of the device and your driving behaviour;
- Provide support services for telematics devices if there are any issues with fitting the device, keeping the device operational and replacement devices, if required;
- 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 any queries you raise via the website.
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.
Consent
- Where we have obtained consent to collect and process your data for a particular purpose. If we rely upon your consent you will be presented with a consent statement prior to you submitting your data to us. An example of this is our use of Cookies in order to monitor the usage of our app and websites to better understand our customer base and their use of our services. Please see our Cookies Policy for further information.
Please note that if consent is the legal basis upon which we process your personal data then you may withdraw your consent at any time. In order to affect this right please contact the Group Data Protection Officer whose details can be found below.
If you would like further details regarding our processing activities please contact the Data Protection and Privacy Office details of which can be found below.
If you would like further details regarding our processing activities please contact the Data Protection and Privacy Office details of which can be found below.
Data Sharing
Your information will only be shared with the following parties:
- The Contracting Entity that provides your insurance policy;
- Third party telematics providers;
- Our third-party services providers such as IT suppliers, actuaries, auditors, document management providers and tax advisers;
- Third parties in connection with any sale, transfer, or disposal of our business;
- We may also disclose your personal information to other third parties where the disclosure is required by law or by a regulator with authority over us on the grounds of substantial public interest.
- Other entities within the Humn Group
Transferring Data Internationally
Data protection law places restrictions on transferring personal data outside of the United Kingdom (UK) and the European Economic Area (EEA).
There may be circumstances where we transfer information to our service providers in countries outside the UK and the EEA. If we do so, then your personal data will only be transferred on one of the following bases:
- where the transfer is subject to one or more of the "appropriate safeguards" for international transfers prescribed by applicable law (e.g. Data Transfer Assessments and Standard Contract Clauses adopted by the European Commission and/or the UK IDTA and UK Addendum as adopted by the UK Government);
- a European Commission or UK Government decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
- there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent).
Marketing Activities
We will only send you marketing information regarding:
- our own products and services;
- industry related insights and news;
- advice for fleet and risk management;
- third party marketing information that you have expressed an interest in receiving.
You have the right to stop the use of your personal data for direct marketing activity. Please contact us if you no longer wish to receive marketing communications.
If you do choose to stop receiving marketing communications from us, we will ensure that you do not receive such material going forward unless you specifically request it in the future.
Please note even although you have opted out of receiving marketing communication from us, we will still continue to send you any necessary information regarding any products of services you continue to have with us or communications we are required to issue in order to fulfil or legal and regulatory obligations.
Security Measures
The safety and security of your data is important to us. As such we are committed to applying the appropriate technical and organisational security measures to meet our legal and regulatory obligations. Our Data Protection Policy and Protocols ensure the principles of Confidentiality, Integrity and Availability form the core structure of our service offering. Our security controls include the following:
- Identity and Access Management, based on strong Authentication (SSO and a Zero Trust Model) and Role-Based-Access-Control to enforce granular access to data;
- Data Loss Prevention, through Backup & Recovery standards as well as Business Continuity & Disaster Recovery procedures;
- Encryption and Anonymisation, leveraging AES-256 based data encryption at rest and TLS v1.3 for data in-transit, whilst utilising SHA256 for PII hashing.
How Long We Keep Your Data For
We will retain your Personal Data for as long as is reasonably necessary for the purposes explained in this Notice. In most cases this will be a maximum of 7 years from the expiry of an insurance contract. In some circumstances we may retain your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.
In some cases we may also retain your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your relationship with us. Where your Personal Data is no longer required we will ensure it is either securely deleted or stored in a way that no longer identifies you.
If you would like further details regarding our records retention then please contact the Data Protection and Privacy Office details of which can be found below.
Your Rights Under The Law
Under data protection legislation you have the following rights:
- The right to be informed – We are required to provide individuals with clear and precise transparency information regarding who we are and what we do with your data. This Privacy Notice along with other transparency information gives effect to this right;
- The right of access – Individuals have the right to access and receive copies of their personal data alongside other supplementary information as required. If you wish to affect this right please contact the Group Data Protection Officer on the details provided below;
- The right to rectification – Individuals have the right to ensure that the information that we hold about them is accurate. If you believe that the personal information that we hold about you is inaccurate or incomplete, then please contact us to request that we amend or update our records;
- The right to erasure – You have the right to request that all data pertaining to you be erased from our systems. Please note that there are certain circumstances where this request may not be possible. If we are unable to comply, we will issue you with meaningful information regarding why this is the case;
- The right to restriction of processing – There may be circumstances where we will restrict the processing of your data. For example, if we are investigating a claim that your personal information is no longer accurate or you object to the processing taking place;
- The right to data portability - You have the right to request that your information be compiled into a common, machine-readable format and either provided directly to you or sent by us to a third-party you nominate. If this is not possible, we will issue you with information setting out why this cannot be done;
- The right to object – You have the right to object to us processing your data or a category of data that we hold about you. If we are unable to comply with your request, we will issue you with meaningful information regarding why this is the case;
- Rights in relation to automated decision making and profiling – As set out above you have the right to request human intervention into any process involving automated decision - making or profiling where that processing results in legal or similarly significant effects. Please note that this right would not apply to underwriting decisions as this automated decision-making is required for entering into the insurance contract however, we would be happy to review your case and provide you with further information regarding the process and your case.
Please note that the above rights are not absolute and requests may be refused where exemptions apply. You can find out more about your rights at www.ico.org.uk
Contact Humn
If you would like further information regarding this Privacy Notice or you would like to exercise any of your data rights, you can contact the Data Protection and Privacy Office by email at privacy@humn.ai or in writing to:
FAO The Group Data Protection Officer
The Data Protection and Privacy Office
Humn.ai Ltd
184 Shepherds Bush Road
London
W6 7NL
The Data Protection and Privacy Office
Humn.ai Ltd
184 Shepherds Bush Road
London
W6 7NL
Changes To This Notice
Humn reserve the right to amend this policy at any time without notice in response to changes in data protection legislation and our legal and regulatory obligations. We recommend that you check our privacy page on a regular basis to ensure that you are aware of any changes which may affect you.
