Privacy Notice for Single Commercial Vehicle Policies

Last Updated: 25 October 2022

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.

If your single commercial vehicle policy is with Kinetiq Underwriting Ltd (The ContractingEntity), Humn process your data as an Independent Data Controller if you have selected their traditional policy or if you have a telematics device fitted as part of your policy.

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 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 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 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;
  • 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.

Data Sharing

Your information will only be shared with the following parties:
  • In the case of drivers, The Contracting Entity that you have a primary relationship with;
  • 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.