THIS FAIR USE NOTICE RELATES TO [VM] INSURANCE AND CALL [VM] FIRST SERVICES.

This Fair Use Notice is to help you understand how we will collect, process and share your personal data. This allows you to make an informed decision as to whether you want to provide us with your data and if you want to give us additional permissions relating to it.

It also sets out your rights in relation to this data and how to complain to the Information Commissioner if you are unsatisfied with how we have handled your personal data.

‍You can update the consents you have given us here link.

DATA WE COLLECT ABOUT YOU.

Data You Provide

We collect the data that you give us when we provide you with a quote or when you make an insurance claim or use the accident aftercare service and any other time that we speak to you or you contact us.

The data we collect from you for a motor insurance quote and in the handling of any claims may include sensitive personal data relating to any convictions you have or that are pending and details of certain medical conditions.

We record telephone calls with you and these call recordings also form part of your personal data.

We also store information about your contacts with us such as the time, length and source of calls, the IP address that you use to access our website, whether you have read or replied to an email we send you; all this data helps us improve our service, detect fraud and resolve complaints when they arise. Our websites may use cookies (small text files) to track and record your activity and to allow us to personalise our websites and enhance your experience of them.

On occasions, you may ask your dealer to provide us with all or some of this data to help you setup a quote, free driveaway cover note, or policy. Where you ask the dealer to do this we treat this as data that you have provided to us and we consider that the dealer has been acting on your behalf in providing us that data.

Data We Collect from Others

As part of providing an insurance quote and administrating a policy including handling a claim we or the insurers we use may collect data from third parties about you including‍

your vehicle manufacturer who may provide details of cars they and their dealers have sold.
suppliers who provide services to you as part of our service such as repairers and roadside recovery agents
other parties to an accident and their insurers
the Motor Insurance Database (MID);
the Claims and Underwriting Exchange (CUE);
the Motor Insurance Anti-Fraud and Theft Register (MIAFTR);
the DVLA and MyLicence, a database that allows us to verify your driving licence details;
credit reference and identity verification agencies;
Lexis-Nexis NCD Database, a database that allows us to verify your No Claims Discount;
emergency services, police, medical and legal practices;

How we use your data.
We will use your data to fulfil requests you make of us and to meet the requirements of any contract we enter with you or any promotion we provide to you.

For instance‍

if you ask us for an insurance quote we will process your data to provide that for you including providing your details to one or more insurers;
if you have an insurance policy with us we will process that data to fulfil our obligations under that contract;
If you ask us to repair your car we will appoint a repairer and provide them with you and your cars details so that they can carry out that repair and pass back to us information about that repair.
If we provide you with an Excess Return or Excess Protect Voucher we will keep a record that you have been issued with it and process your data in connection with it.

Additionally, we will process your data to fulfil our legitimate interests where they are not overridden by your interests. This includes:

If you have asked us for a quote or received a product or service from us, then we may contact you to let you know of similar products and services that we provide from time to time. You can opt out of this at any time (link) and any such communication will let you know how to do that easily.
Inviting renewal of your policies or Excess Return or Excess Protect Voucher;
Contacting you to assist you when you are accessing our services online;
Letting you know when a cover note is going to expire and providing you with a means to take up a full motor insurance policy;
Administering our business including:

Motor insurance policy pricing and underwriting
Fraud prevention and detection
Debt recovery
Verifying your identity
Carrying out customer satisfaction surveys
Resolving complaints
Researching new products
Evaluating new insurers and suppliers

To enable us by way of analysis to improve and develop the services we provide;
Using automated means, to decide what products and services you may be more likely to be interested in or how we administer products and the service we provide to you;
Updating you on promotions that you have participated in where we may contact you to remind you of the benefits you could receive;
Letting your vehicle manufacturer and/or your franchise dealers know the take up of the products that they promote and to share with them details of complaints and other feedback you might provide about our services;
To contact you to let you know about significant updates to this Fair Use Notice (you can check back here anytime to see the current version).

Additionally, should your vehicle manufacturer appoint another company to provide their branded motor insurance in our place, and where you have an active branded motor insurance policy then we will provide your data to that company solely for the purpose of them providing you with a branded motor Insurance renewal quote.

You can ask us not to process the data in any of these ways and we will consider your request fairly (see your rights to object to processing of your data below)

Additional Data Permissions
If you have not asked us for a quote or received a product or service from us we will only promote additional products and services to you where you have given us your consent. For instance, if you give us your renewal date we will consider that consent to send you a quote near the time of your renewal. You can update the consents you have given us here link or by calling us on 01923 692 000.

When you report a claim to us or use our Accident Aftercare service we will share certain data with your franchise dealer, but we will only do that if you give us permission at the time you report the incident to us.
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Who else will we provide your data to?We, or the insurers that we deal with, may provide your data to certain third parties in relation to the services that you request from us or that are covered by an insurance contract or promotion you have participated in.

These include

your vehicle manufacturer and your franchise dealer Dealer;
insurers;
our approved suppliers including

Claim administrators, loss adjusters, recovery agents
approved repairers and network managers
premium finance providers
companies providing customer satisfaction surveys and ecommerce assistance.
marketing companies that assist us marketing our products and services
IT providers

providers of Regulatory Compliance Services;
the Motor Insurance Database (MID);
the Claims and Underwriting Exchange (CUE);
the Motor Insurance Anti-Fraud and Theft Register (MIAFTR);
Lexis-Nexis NCD Database, a database that allows us to verify your No Claims Discount;
emergency services, police, medical and legal practices; and
our professional advisers

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Transfer of data outside of the UK and the EU.
We use servers located in the UK to store your personal information or elsewhere in the EU where it is protected by laws equivalent to those in the UK.

Some of our suppliers and insurers from whom we source insurance quotes may transfer your personal information outside the EU, where this is the case our contracts with such suppliers require them to provide equivalent levels of protection for your personal information as it would have anywhere in the EU.
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How long will we keep your data?
Where you do not enter into an insurance contract with us we will delete or anonymise your data during the [third] year after you last provided it to us or updated it unless there is a reason to hold it for longer, such as you made a complaint that was not resolved quickly.

Where you enter into an insurance contract, including a Covernote, arranged by us we will need to hold your data for the period that a third party is entitled to notify a claim under that policy which can be brought many years after the event, however we will pseudo anonymise your data in the [third] year after the expiry of your policy. That means it will be held in our systems in such a way that your data cannot be identified except by reference to a separately held and secured data file.

YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

You as someone whose personal data we process have certain rights as to how we process it; namely:You as someone whose personal data we process have certain rights as to how we process it; namely:

How we use your data.
You are entitled to be informed in a transparent manner about the processing of your data and that is what we have set out in this Fair Use Notice. If you have any questions about how your data is processed then please contact us on [telephone number] and we will try to answer your questions.

The right of access
You are entitled to know what data we are processing and to receive a copy of it. You can request this from us at any time. This is known as a Subject Access Request and in normal circumstances we cannot charge you for providing you with a copy of your personal data that we process. We will normally provide you with a copy of your data within one month of receiving your request.

The right to rectification
You are entitled to have corrected any incorrect or incomplete information that we hold on you.

The right to be forgotten
You are entitled to request that we delete your personal data where we no longer have a legal basis for processing it. We will delete your data if you request that we do so and if:

It was no longer necessary for the purpose you gave it to us,
We were processing it based solely on your consent and you have withdrawn your consent; and
There is no overriding legitimate interest for us to continue to process it.

The right to restrict processing
You are entitled to request that we restrict the processing of data so that we only store your data and not process it further and we shall comply where one of the following applies:

the accuracy of the personal data is contested by you, for a period enabling us to verify and or rectify the accuracy of the personal data;
we have processed the data without a lawful basis and you do not wish us to delete it and have asked that we restrict its use instead;
we no longer need the personal data for the purpose originally intended, but you want us to retain it in relation to a legal claim;
you have raised an objection to the processing of the data and we are in the process of considering whether to agree to that objection.

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The right to data portability
You are entitled to request and to receive your personal data that we process in a reasonable electronic format so you can reuse it or provide it to a third party for them to reuse it for you. You are entitled to receive this data free of charge and within one month of your request.

The right to object
You are entitled to object to our processing of your personal data for our legitimate interests beyond that which is strictly necessary in relation to a contract you have entered in to. If you make such a request we will either agree to your request or let you know any reason we have for not agreeing to it.

Where we have passed your data to another party and you make a request to exercise your rights in relation to that data we will endeavour to pass on your request to all such third parties who will be similarly obliged to treat your request in accordance with your rights as a data subject.

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Your right to lodge a complaint with the Information Commissioner.
You are entitled to make a complaint to the Information Commissioners Office which you can do:

via their website here; or
by calling 0303 123 1113 or 01625 545 745; or
by writing to
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

This Fair Use Notice was last updated on 6th February 2018

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