Privacy Notice for Website Users
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 individuals using our website, including contact us using one of the forms on our website.
How We Receive This Information
When you use our website we automatically collect information about your browsing session such as your IP address and the type of device you are using. We also keep track of the pages you view during your visit. We use this information to improve the way our website operates and for system administration purposes. For more information, please see our Cookie Policy.
If you submit an enquiry via the forms on our website, we will collect information about you including your name, email address and details relating to your enquiry.
We will use this information to respond to your enquiry. If your enquiry relates to one of our products or services, you should read the relevant Privacy Notice for more information about how we use your information in relation to those products or services.
If you complete a form to subscribe to emails or enter a competition, we will collect information about you including your name, email address and other information specified on the form. We will use this information only as specified as to the purpose of collecting the information.
If you submit an enquiry via the forms on our website, we will collect information about you including your name, email address and details relating to your enquiry.
We will use this information to respond to your enquiry. If your enquiry relates to one of our products or services, you should read the relevant Privacy Notice for more information about how we use your information in relation to those products or services.
If you complete a form to subscribe to emails or enter a competition, we will collect information about you including your name, email address and other information specified on the form. We will use this information only as specified as to the purpose of collecting the information.
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 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 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
- Our third-party services providers such as IT suppliers, actuaries, auditors, marketing agencies, providers of market research services, including customer feedback surveys, referral administrators, 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.
If you would like further details in relation to how we share your information and with whom please contact the Data Protection and Privacy Office details of which can be found below.
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 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 Privacy Notice at any time without notification in response to changes in data protection legislation or in order to fulfil our legal and regulatory obligations. We recommend that you check our privacy information on a regular basis in order to ensure that you are aware of any changes which may affect you.
