App Privacy Policy

This privacy notice tells you what we do with information we collect about you when visiting our website and using our App. It's relevant to anyone who uses our services from Direct Line Group plc, including policyholders, prospective policyholders, website and app users and beneficiaries under our policies, such as named drivers. We refer to all these individuals as "customers" or "you" in this notice.

We are U K Insurance Limited ("we", "us" or "our") and you will know us by our brand names:

Churchill, Direct Line, Privilege, Darwin and Green Flag.

Visiting our website and using our App

When you open the website or app, then we may store or retrieve information about you and your device. The information is mostly used to make the website and app work as you expect it too. For example:

technical information about your device such as operating system and platform;
services you viewed or searched for; and
response times, download errors, length of visits to certain pages, interaction information (such as scrolling and clicks), and methods used.

Some of these cookies are necessary for the website and app to function such as to ensure you can move between our pages and screens quickly and effectively. You can control the non-essential information that is shared from your device or browser by adjusting your Cookie settings or changing your preferences within the app or browser. Please refer to our Cookie Policy for more details on the types of technologies we use on our website and app.

Information collected from others

We can collect information about you from others. This includes information from:

Joint policyholders or policy beneficiaries. Where you are named on a joint policy or a beneficiary of that policy we may collect information about you from any named policyholder. We will ask them to confirm that they have your permission to give us this information about you.
Fraud prevention, law enforcement or government agencies and other data sources e.g. social media or other information-sharing platforms. Please see section 3 c for more details.
HM Treasury and other authorities in relation to regulatory issues e.g. where someone is subject to a financial sanction they will appear on HM Treasury's asset freezing list.
Credit reference agencies e.g. credit searches that are made when we produce a quotation for a new policy or at renewal. (Note that the results of these searches are automatically deleted after 12 months and do not affect your ability to obtain credit.) Please also see section 4 below.
Driver and Vehicle Licensing Agency (DVLA). We may ask for your Driving Licence Number (DLN) and the DLN of any named drivers as part of your application for motor insurance. The number is used to do an automated check with the DVLA driver database to retrieve the licence status, licence entitlement, relevant restriction information and any endorsement and conviction details. If you do not wish to provide your DLN you can choose to answer the questions about your licence information yourself.
Driver and Vehicle Standards Agency (DVSA).
External sources such as no claims discount databases, the electoral roll and insurance comparison websites to help us decide what the risk is in selling the policy and from companies that hold information about insurance renewal dates, marital status, household residents, vehicle details, employment status and household income to help us work out which information we should provide to you about our other products and services.

Sensitive personal information

We collect information that is sensitive, such as information about health or unspent past criminal convictions or offences.

We may also collect information which due to its nature requires additional protection, such as information related to children, biometric (voice recognition and facial images) data and geo-location (which could for example reveal medical or religious locations although we never use this information). We may collect your sensitive personal information for specific types of policy or applications, for example when offering you a travel policy or a driving application e.g. Telematics. We obtain this from your mobile devices for driving applications and the following people:

The main policyholder will provide most of the information we collect about health (including confirming whether hospital treatment is being sought) and unspent criminal convictions or offences, including on behalf of others named on the insurance policy e.g. medical screening to support a travel policy;
Fraud prevention or law enforcement agencies may provide details to us about criminal convictions or offences;
Witnesses to an accident may provide medical information to us if there is an investigation of a claim;
We may use information about a child, for example, where the child is a beneficiary under a policy or if involved in an accident.

We collect and use this information as part of your insurance quotation or contract with us, or where it is necessary for a legal obligation, or as part of the establishment or defence of a legal claim.

We may also use your biometric data (voice recognition and facial images) to check your identity. When we do so, we will explain to you why we need it, and where necessary obtain your consent to use it for the relevant purpose. Biometric data may also be used to prevent or detect fraud.

We use your personal information in order to meet our obligations in our contract of insurance with you. We and other companies within our group of companies use your personal information in the following ways:

A. Provide insurance services

When you request us to provide you with a quote for one of our insurance policies or you purchase an insurance policy from us, we use information about you:

To decide what the risk might be in selling you the policy, to quote for, and provide you with, a premium for that policy and any special terms that may apply to that policy (noting that we may use automated decision making to make this assessment - see section 9 below);
To administer your policy and monitor the payment of instalments if you pay your premium in this way;
To contact you about the policy (e.g. for billing or renewal purposes); and
To provide the agreed service if you make a claim (e.g. sending someone to assist you in a roadside breakdown situation or to provide you with medical assistance if you are injured or unwell when overseas).

We cannot provide the services unless we use the information about you in this way.

B. Do what we are required to do by law

As part of our duty as an insurer providing insurance services, sometimes we are required by law to use information about you:

To help make sure our customers are being treated fairly (e.g. to assist our regulators or suppliers where we have a legal duty to do so) or to help identify if it is necessary for us to make adjustments in our service to aid and meet the needs of vulnerable customers);
To deal with complaints;
To help prevent and detect crime (including, for example, the prevention or detection of fraud); and
To comply with a legal or regulatory obligation.

We can use your personal information in this way because we are required to do so by law.

C. Prevent fraud occurring

Fraud has an impact on all customers as it increases costs for everyone. We use your personal information to check for signs that customers might be dishonest (e.g. if someone has behaved dishonestly in the past it may increase the risk they will do so in future).

We may use your personal information in this way because it is in our interests to detect fraud and in all our customers' interests to ensure that they are not prejudiced due to increased premiums as a result of a few customers acting dishonestly.

D. Recover debt

If you owe us money we will use your personal information to help us recover it.

We can use your personal information in this way because it is a necessary part of the contract of insurance. We need to ensure that premiums are paid so that the majority of our customers do not suffer (e.g. through increased premiums) due to the actions of a small minority of customers.

E. Direct Marketing

Keeping in touch

From time to time, we may send you marketing regarding any of our products, discounts, offers and services where we believe you will have an interest in the communications. These updates will come from brands and companies in the Direct Line Group.

These communications will be sent and displayed to you based on your preferences:

With your consent we will send your direct marketing via email, text messages or display this information to you in your social media channels or web browser.
We will contact you by phone or post to let you know about products our services unless you've told us you'd prefer we didn't contact you in this way.

You can let us know at any time if you no longer wish to receive marketing messages. The simplest way to do this is to click on the unsubscribe link on emails or respond using the return address on the envelope. You can also contact our Data Rights Team, please see section 10 for contact information.

We will keep a note of your earlier marketing preferences for six years. If you have chosen not to receive marketing, we will not contact you unless you tell us you have changed your mind.

Making our communications relevant to you

We process your personal information to evaluate the effectiveness of our advertising and help us provide more relevant offers and information across a variety of marketing channels including online advertising and social media sites such as Facebook.

In certain circumstances we use publicly available or licensed sources of information to enhance the personal data we hold about individuals or groups or individuals.

We analyse our customer database and external data sources to understand who customers are and how they interact with us. In doing this, we can improve our communications by identifying new audiences, ensuring our communications are relevant to you and allow us to be more efficient and cost-effective with our resources.

To help us recognise how recipients interact with our email communications and enhance their display on various devices, we employ a widely recognised method of embedding an image pixel within our emails to collect information about when you open the email such as your IP address, your browser or email client type. If you don't want us to use tracking pixels, you can use your email settings so that images are not automatically displayed.

We also provide you with a personalised online experience by giving you marketing based on your interactions with us and analysis of your customer behaviour on our websites, such as your purchase and browsing history. Learn more about our use of cookies and similar technologies in our Cookie Policy.

F. Where your or another person's life may be at risk

We will use your personal information to assist where your or another person's life or health is in danger and obtaining your permission is not possible (e.g. arranging emergency medical treatment in a remote location).

G. To administer and improve our services

To administer our services we will share information with others (including to people or organisations that may be based overseas):

In order to enable us to process your claim or administer your insurance policy more cost effectively, we may share your contact details within UKI to help you with a claim you may have against another customer of UKI. This can include proactively contacting you to offer our services;
To help develop our products, services and systems to deliver you a better sales and claims experience in the future.

H. To improve our services

We may use technology to evaluate opinions you express, including any verbal or written feedback and opinion, to improve our customer experiences, including:

Recording our calls for training and administration purposes;
To provide and offer more relevant products;
To improve our written and online communication for our customers;
To ensure our staff provide a high level of customer service.

We may also process your personal data to better understand you as a customer, including to determine how best to retain your custom, and to ask you to provide feedback on the service we provide to you.

We can use your personal information in this way because it is in our legitimate interests to provide the services in the most efficient way. We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to achieve this efficiency.

We may share your personal information with third parties and other companies within our group of companies for the purposes mentioned in Section 3 above. A list of our group companies can be found at https://www.u-k-insurance.co.uk/group-companies.html. Alternatively, you can contact the Data Protection Officer for a list of them. Please see section 10. You should make sure everything you tell us is correct because your records may be checked in the following circumstances:

When you apply for insurance, financial services, or work
By police and other law enforcement agencies.

In particular we share information with:

Fraud prevention agencies that provide databases and services, such as CIFAS, National Hunter, SIRA and ENI, to prevent or detect fraud.
- Fraud prevention agencies will process this personal information in order to assist our prevention of fraud and money laundering, and to verify your identity and may also process your personal information in order to prevent fraud and money laundering by other people.
- Fraud prevention agencies will hold your personal information for up to 1 year, or up to 6 years if you're considered to pose a fraud or money laundering risk.
- If we or a fraud prevention agency determine that you pose a fraud or money laundering risk, we may refuse to provide the services and / or financing you have requested.

A record of this risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services or financing to you. If you have any questions about this, please contact the appropriate fraud prevention agency.

Law enforcement or government agencies we and fraud prevention agencies may permit law enforcement or government agencies to access and use your personal information, if they request it.
Regulatory bodies such as the Financial Conduct Authority, Prudential Regulation Authority or the Information Commissioner's Office to meet regulatory and legal obligations and requests for information.
Credit reference agencies are used to help us verify your identity, and to determine the price of your insurance and your payment options when you take out a quote and at renewal of your insurance policy. This leaves a "soft footprint" on your credit file which can only be seen by you and does not affect your credit score.

If you choose to pay your premium by instalments we will share this information when you first take a policy with us and at each renewal. We may exchange your personal information with credit reference agencies to reflect your credit application (as payment by instalments means that there will be a credit agreement between us). We will let you know before we do this. This will be visible to other credit providers and is known as a "hard footprint". Failure by you or anyone who pays for your policy to keep up the monthly payments due under your credit agreement will be reflected in your credit score, not theirs.

The identities of the credit reference agencies and the ways in which they use and share personal information are explained in more detail at www.experian.co.uk/crain/. Alternatively, you can call us and we will send you a copy.

Business Insurance Credit reference agencies are used to help us verify your and any joint policyholder's identity, and to determine the price of your insurance and your payment options when you take out a quote and at renewal of your insurance policy. This leaves a "soft footprint" on your and any joint policyholder's credit file which can only be seen by you and does not affect your credit score.

If you choose to pay your premium by instalments, we will share this information when you first take a policy with us and at each renewal. We may exchange your and any joint policyholder's personal information with credit reference agencies to reflect your credit application (as payment by instalments means that there will be a credit agreement between us). We will let you know before we do this. This will be visible to other credit providers and is known as a "hard footprint". Failure by you or anyone who pays for your policy to keep up the monthly payments due under your credit agreement will be reflected in the credit score for your business, and the ability for your business to obtain credit in future, not theirs.

The identities of the credit reference agencies and the ways in which they use and share personal information are explained in more detail at Credit Reference Agency Information Notice (CRAIN) | Experian. Alternatively, you can call us, and we will send you a copy.

Your spouse or partner who calls us on your behalf, provided they are named on the policy. Please tell us who they are when you take out your policy. If you would like someone else to deal with your policy on your behalf on a regular basis please let us know. In some exceptional cases, we may also deal with other people who call on your behalf, but only with your permission. If at any time you would prefer us to deal only with you, please let us know.
Joint account holders where insurance products are affiliated to a joint account personal information will be visible to both account holders; this will include details such as your name and address.
Other insurance companies and third parties to help settle any insurance claim or to verify that the information you have provided is correct (e.g we will check the amount of No Claims Discount you have told us with your previous insurer). Or where required or appropriate in connection with a proposed or actual sale, merger, acquisition, reorganisation, business transfer, financial arrangement, asset disposal or other corporate or financial transaction relating to our business and/or assets held by our business. Where such data is shared with a third party in connection with these transactions, it is done so under duties of confidentiality.
Insurance industry bodies such as The Motor Insurance Database to meet our obligations under the Road Traffic Act.
Insurance industry databases, such as the Claims and Underwriting Exchange where you make a claim so that insurers can check that your claims history is correct, the Insurance Fraud Register, the Cache Pet Bureau Services database and, for commercial policies, the Employers' Liability Tracing Office.
Data verification and information. We share information concerning your request for a quote and your insurance policy with LexisNexis Risk Solutions who help us to check your identity and evaluate your insurance risk. LexisNexis Risk Solutions Limited does this by collecting data about you from public sources (such as the electoral register and insolvency service) and private sources (such as other insurers). More information on LexisNexis Risk Solutions Limited and how it collects and processes your data, your right to object and your other data protection rights is available here at https://risk.lexisnexis.com/group/processing-notices/insurance-services
Government bodies, such as the Driver and Vehicle Licensing Agency.
Driver and Vehicle Licensing Agency (DVLA) data If you choose to provide your Driving Licence Number (DLN) as part of your application for motor insurance the data provided by the DVLA may be used alongside other information you have provided:
- To provide you with a quote;
- To administer the policy; and
- To prevent fraud.

The data will not be used for any other purpose, or be made available to anyone else. Searches of the DVLA driver database may be carried out prior to the date of the insurance policy and at any point throughout the duration of your insurance policy including at the mid-term adjustment and renewal stage. Unlike other DLN searches with the DVLA that you may have authorised, this one will not show a footprint against your driving licence.

MOT data will be collected from the Driver and Vehicle Standards Agency (DVSA) and be used during your policy term with us. Whilst this will not affect your initial quote, the MOT data may be used throughout your policy. It is important to keep your vehicle MOT up to date as missing or incomplete MOT data could result in a decline later in your policy term. The MOT history service contains public sector information licensed under the Open Government Licence.

Advertising Partners We partner with advertising companies, including social media sites, addressable TV providers and third-party websites, to display adverts about our products and services.

Our Advertising Partners enable us to identify and engage with the right target audience, to create and distribute personalised content across platforms and services. For example, addressable TV providers allow us to customise the adverts displayed to individual households while they are watching the same programme.

They use techniques like device recognition and interactions with social media content to tailor ads, but they don't target individuals by name. In most cases, cookies and similar technologies such as device fingerprinting are used to target this type of advertising. To learn more and manage their use, refer to our cookie policy.

We may share personal information, e.g., an encrypted email address or device id, with our Advertising partners. The purpose is to show relevant ads to you on third party websites and apps. To do this, your data is matched with the database of the Advertising partner. If a match is found, you will receive relevant promotional content in your feed or search engine. If no match is found your data is securely destroyed. Your personal data is handled in a secure manner using a technique called hashing. This ensures your data is scrambled in a manner that makes it unreadable to anyone other than the recipient.

We may send your personal information overseas to any part of the world to administer your insurance policy or insurance claim. The protections given to your personal information in other parts of the world may not be as strong as in the UK. Where possible, we will put in place agreements with the people we send your personal information to, to require them to treat your personal information with the same protections that we apply ourselves.

Our agreements may include standard terms called Standard Contractual Clauses or International Data Transfer Agreements (IDTAs) approved by the UK Information Commissioner's Office or may require the other party to be signed up to government standards that are recognised as providing the right level of protection. But it is possible that regardless of what is set out in the agreement this would not stop a government in any part of the world from accessing your personal information, as they can often have power to overrule any agreements we make, for purposes such as crime prevention and national security.

In some cases we might need to share information to carry out the services we have promised to carry out, for example if you require urgent assistance abroad. In such an urgent situation we may not always have the time to put in place the type of agreement we would normally want to; however, we will ensure that if such a transfer is required that it complies with the standards required by data protection legislation.

We are only allowed to keep your personal information if we need it for one of the reasons we describe in section 3 above.

As a general rule, we will keep it for 6 years from the end of your relationship with us, as it is likely that we will need the information for regulatory reasons, fraud prevention, or to defend a claim. For example, should you wish to bring some form of legal action relating to your relationship with us, this would generally need to be done within 6 years from the end of that relationship. However there may be exceptions where we need to keep your personal information for longer, such as where a claim has involved a minor.

We will also retain data in an anonymous form for statistical and analytical purposes, for example, to assess risk of flood damage occurring.

If we rely on your consent to collect and process your personal information, you can ask us to stop using your personal information at any time by withdrawing that consent and we will stop using your personal information for those purposes.

At any time, you can tell us to stop using your personal information to:

Tell you about products or services that may be of interest to you
Allow computers to make decisions about you in order to improve our services or develop our products (see section 9).
Create and use customer profile for direct marketing purposes

To find out how to do this, please see section 10.

Where you do not provide the personal information we need in order to provide the service you are asking for or to fulfil a legal requirement, we will not be able to provide the service that you are asking us to give you.

We will tell you about why we need the information when we ask for it.

We will collect information about you and put this into our computer systems. The computer systems will make certain automated decisions about you which will be based on comparing you with other people. This will have an impact in terms of the level of premium or product that we offer to you or the products or services that we decide to tell you about. We may also use automated decision making to conduct an identity verification check.

For example, if you are under 25 years of age, the computer system may determine that you are more likely to have a car accident. This is because the computer system has been told that more people aged under 25 have car accidents. Another example is that, if you are under 25, the computer system may determine that you are going to be interested in a travel policy which covers high risk activity, such as skiing. Therefore, we would proactively seek to tell you about such policies as we would consider them to be of interest to you.

This is important because:

In providing insurance services it helps us decide what price you should pay for your policy and understand any risks associated with that policy;
In identity verification it helps us to check that you are who you say you are and to prevent others from imitating you;
In selling you other products it helps us decide which other products might be useful to you.

We also use computer systems to carry out modelling. Sometimes using your personal information and sometimes using data in anonymised form. We conduct this modelling for a variety of reasons, for example, for risk assessment purposes to make decisions about you, such as your likelihood to claim. However, we may also use your personal information in that modelling to make decisions about how we improve and develop our products and services, or our pricing and underwriting, or to better understand how our prospective customers make decisions about which policy is the optimal policy (i.e. we are not making decisions directly about you).

Our Data Rights Team are responsible for responding to your requests to exercise your rights which are set out below. The Data Rights Team may be contacted at U K Insurance Limited, Churchill Court, Westmoreland Road, Bromley BR1 1DP, by email at Data.Rights.Requests@directlinegroup.co.uk or through this form: https://www.u-k-insurance.co.uk/data-rights-request.html

You may contact us at the address above for one or more of the following reasons:

To ask us to correct information about you that is wrong or incomplete,
To ask us to delete personal information about you (the "Right to Erasure"). We are not required to erase information if we still need it for the purposes for which it was collected or processed, including to maintain records after cancellation or expiry of your policy, or where we have other legal grounds for processing your information.
To tell us you no longer agree to, that you object to, or that you wish to restrict us using information about you and ask us to stop.
To tell us to stop using your personal information for direct marketing purposes.
A right of access, namely to ask us to provide you with a copy of all of the personal information that we have about you.
A "data portability" right, namely to obtain and reuse the information that you have provided to us for your own purposes across different services. You may ask for this information to be provided directly to you or directly to another organisation. We will provide the information in a machine readable format so that another organisation's software can understand that information.
To ask us to review automated decisions made about you (as explained in section 9).

Sometimes we will not be able to stop using your personal information when you ask us to (e.g. where we need to use it because the law requires us to do so or we need to retain the information for regulatory purposes).

In other cases, if we stop using your personal information, we will not be able to provide services to you, such as administering your insurance policy or servicing your claim.

We will tell you if we are unable to comply with your request, or how your request might impact you, when you contact us.

Complaints

If you have any concerns about the way in which we are using your personal information, please contact our Data Protection Officer in the first instance at U K Insurance Limited, Churchill Court, Westmoreland Road, Bromley, BR1 1DP or alternatively by email at DataProtection@directlinegroup.co.uk and we will endeavour to resolve your concern. However, you do also have the right to complain about how we treat your personal information to the Information Commissioner's Office ("ICO"). The ICO can be contacted at:

ICO website: https://ico.org.uk/global/contact-us/

ICO telephone: 0303 123 1113

ICO textphone: 01625 545860