DrivePlus Telematics App Privacy Notice

This Privacy Notice explains how we and our technology suppliers will collect and use the journey data gathered by the DrivePlus App.

It is important that you are aware that journey data will be collected and transmitted any time the DrivePlus App is enabled.

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

Churchill, Direct Line, Privilege and Green Flag

You should also read the Privacy Notice provided with your motor insurance policy documents, as it explains how we will use the information that you provide us and that we collect from you. You can find information on your rights, how to contact us and make a complaint in this notice.

Once activated the DrivePlus App will record and analyse your journey data and your driving behaviour. All of your Journey data will be collected and retained by the app, whether you are a driver or passenger. Passenger journeys can be excluded from your driving scores by tagging your journey. The DrivePlus app only starts recording when you’re travelling at a minimum speed and will stop recording when your journey ends. We do not record you 24/7.

It will capture and send your specific location, direction, current speed; duration of journey; braking and cornering, mobile phone usage while driving, amongst other factors to our technology supplier’s server and we will use the information to understand road type, speed and other conditions relating to your journey. This information will be used to build up a profile of how, where, when your car is driven and the level of mobile phone distraction. This information will be combined to form a driving score based on your driving behaviour.

We will use the journey data from the DrivePlus App for assessing individuals' driving behaviour and to provide insurance policies which are reflective of driving behaviour as well as other rating factors.

Your data may be used for the following purposes:

• To help us to understand safe driving behaviours, which we will use to develop underwriting of our motor insurance policies and to inform our development of similar products, services and systems;
• To help to determine or corroborate the circumstances of a claim, loss or theft;
• To help prevent and detect fraud;
• To tailor your premium at renewal.

We will use your information in this way so that we can administer your DrivePlus App policy and assess your driving score to determine the risk you pose as a driver. This will influence the insurance premium you pay.

We will collect, process and retain your personal and journey data including instances where you may be a passenger in another vehicle or using another form of transport, in accordance with data protection legislation and our policies on data retention. This enables us to service your Telematics policy and improve our Telematics pricing models and Tagging algorithms. From the end of each of your telematics policy year, we will retain your data for six years. After six years we will either delete or completely anonymise your data and so it is no longer identifiable to you. This allows us to use the journey anonymised data for statistical and analytical purposes.

When you give us your information, it will be shared with our technology supplier.

The information collected by the DrivePlus App will be used by our technology supplier for research and analytical purposes both during the active period of the DrivePlus App, and after your use of the DrivePlus App has ceased. Any information that our technology supplier shares with third parties will be made anonymous and will not contain any of your personal information. This will prevent personal data or journey data results being directly linked to you.

Our technology supplier will use your personal data for communications that relate to your DrivePlus App participation and will use your journey data for the purposes below.

• Road and vehicle usage including for road safety issues, real time traffic flow, environmental impacts such as idle time at junctions, journey times, distances and speeds, and the analysis of junctions and the risk they represent;
• Driving behaviour analysis and profiling including determining what constitutes safe and dangerous driving and the typical behaviours of various segments of the UK population;
• Analysis of the causes of, and forces involved in, collisions and other road incidents; and,
• Researching and refining techniques for analysing motor vehicle telematics data.

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

If you wish to cancel your participation in DrivePlus App, your account will be deactivated and data collection will stop within two weeks from the point of cancellation

Information recorded from your DrivePlus App will be assessed automatically to generate your driving score. This score will be based upon a review of your specific location, direction and current speed and the level of your mobile phone distraction, as well as information to understand road type, speed and other conditions relating to your journey. The driving score will be assessed against our internal models of driver behaviour to generate a driving score. This score can be accessed via your DrivePlus App.

The driving score will be used within our pricing systems to determine your renewal premium

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 by email at data.rights.requests@directlinegroup.co.uk.

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

1. To ask us to correct information about you that is wrong or incomplete.
2. 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.
3. 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.
4. To tell us to stop using your personal information for direct marketing purposes.
5. 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.
6. 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.
7. 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.