Privacy Policy 


We have a duty to keep your information safe and to inform you on how we collect, use and share your information. 

We handle your data how we’d like companies to handle ours: we don’t sell it and we’ll always give you complete control over it. As far as we’re concerned, your data’s your property and you kindly allow us to use it so we can bring you Kudo products. 


Who we are  

We are Kudo, which is a trading name for Toggle Data Services Limited; we are the data controller of the personal data we process about you for the purposes of this insurance. Our registration number with the Information Commissioner's Office is ZA774590. 

We will share data relating to your policy with Calpe Insurance Company Ltd who will also be a data controller of your data. You can read further about how Calpe Insurance processes your data by reading their privacy notice at 


Your personal data  

The data we hold on you will include:  

  • The data you provide to us via the App or your phone in order for us to provide insurance to you 

  • What you have done and what has happened while you are with us. For example, any claims or policy amendments you have made, as well as how you have engaged with the app 

  • What we have been told about you by other organisations and companies detailed in this notice 

  • Special category data and Criminal Convictions Information may be collected from you in order to provide and administer your policy 


Where we process your personal data, including personal data of other individuals, we do this on the basis of contractual relationship. This processing is therefore required in order to provide and administer the contract of insurance. 

Where we process special category data and criminal conviction information we do so on the basis of public interest for the purposes of the contract of insurance. 

We will sometimes need you to provide us with data about other people, for example where another person is being added to the policy as a named driver. Where you give us data about someone else, you must make sure that you have made that person aware of this privacy notice. If we ask you to confirm your consent to certain data being processed, you are giving consent for your data and any relevant data relating to the other person to be processed.  


How we use your data  


We use your personal data to:  

  • Provide you with an insurance quote  

  • Administer your insurance policy  

  • Manage your claims  

  • Operate your Kudo reward program  


For example, we will use your information to assess your financial and insurance risk, to help prevent crime such as fraud and money laundering.   


Who we may share your information with  


In order to provide you with a quote or the administration of your policy, including amending and renewing, we will exchange information with other companies and databases as is standard practice within the insurance industry.  

These companies and databases may include:  

  • Our data enrichment provider LexisNexis ( concerning your request for a quote and your insurance policy who help us to check your identity and evaluate your insurance risk. They do this by collecting data about you from public sources (such as the electoral register and insolvency service) and private databases (such as other insurers). For more information on LexisNexis, how they collect and process your data, your right to object and other data protection rights, please visit

  • Our insurance policy administration provider Instanda (

  • Our telematics provider We share details of driving behaviour for all people named on the policy, including location and motion. 

  • Our credit reference agency – see for further information 

  • Third-party organisations we may get information from, or who we may share information with, including the Motor Insurance Database, Claims and Underwriting Exchange; and anti-fraud databases such as SIRA, CarWeb, Thatcham, and PlateRecogniser 

  • Public sector/ government organisations such as the Financial Conduct Authority (FCA), the Financial Ombudsman Service (FOS); the police; Trading Standards 

  • Our customer support and messaging platform Intercom ( . We provide a limited amount of your information and utilise Intercom to collect data for analysis and support purposes when you visit our website or use our app 

  • Fraud prevention organisations and agencies such as the Insurance Fraud Register; Claims and Underwriting Exchange (CUE), the Motor Insurance Anti-Fraud and Theft Register, and SIRA 

  • If we find that you’ve provided false or inaccurate information to us we may pass your details to fraud prevention agencies. To prevent fraud and money laundering, we and other organisations, including law enforcement agencies may also access and use information recorded by fraud prevention agencies, for example, when: 

  • Checking details on applications for credit, credit-related or other facilities 

  • Managing credit and credit-related accounts or facilities and recovering debt 

  • Checking details on proposals and claims for all types of insurance 

  • Completing credit and fraud searches, such as driving licence checks, and credit checks as part of our premium finance facility 

  • Our payment service provider Stripe ( Your use of Stripe is governed by their Terms of Service 

  • Professional auditing bodies for auditing purposes 

  • To our operational partners who provide the product and services to you 

  • If we are required by law to disclose this information, such as to regulators or to the police. We will not pass any telematics device data to the police unless required to do so by law, or if you provide us with authorisation to do so 


Further details on these databases can be found at:, 

For all suppliers, including any we use outside of the UK, we will only share the information they need to provide their service. When we use these suppliers, we require that they sign up to the same data and privacy policies that we have. We will not share your information within anyone else unless:  

  • We have your permission  

  • We are required or allowed to do so by law  

  • We transfer rights and obligations allowed under this notice  


Fraud and money laundering  

In order to prevent and detect fraud, we may use your personal data to undertake searches to prevent fraud and money-laundering and to verify your identity. This will include sharing your details with credit reference agencies and fraud prevention agencies.  

If false or inaccurate information is provided or if we determine that you pose a fraud or money-laundering risk, we may refuse to provide the product you have requested and we may stop existing services to you.  

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and which may be checked by other organisations. This may result in you being refused services or products from them.  


How we deal with other people  


In order to protect your personal data: 

  • We will only discuss your policy with you, unless you tell us otherwise 

  • We will only undertake actions on your policy, for example changes and renewal, following notification from you 

  • You may provide authorisation to your spouse or partner to act on your behalf, provided they are named on the policy 


Your rights 


Data Protection law provides you with various rights in relation to your personal data. All rights detailed below can be exercised by contacting us using the details set out in this notice.  

  • You have the right to request a copy of your personal data that we hold about you. This is called a Data Subject Access Request. 

  • You have the right to ask us to correct inaccurate personal data that we hold about you. You will need to verify your identity and evidence the inaccuracy for us to update and correct the information. 

  • You have the right to request that we delete the personal data we hold about you. We are obliged to delete personal data where there is no legitimate business reason for continuing to hold your data.  

  • You have the right to ask us to not do anything with your personal data except store it in limited circumstances. For example, where you and us do not agree on the accuracy of personal data and further validation is required 

  • You have the right to object to us processing certain personal data about you. For example, you can ask us to stop processing your data for marketing purposes.  

  • You have the right to ask to review any significant decisions we have made about you wholly by automated means. The nature of the quotes we provide means we have to use this kind of automated decision making in relation to your personal data. 


If we change something  

Sometimes we may need to change the way we use your information. If this change is different from what is outlined in our Policy Booklet, we will inform you first. 


Contact information  

If you would like more information about this notice or to exercise any of your rights detailed above, please contact us:  

Data Protection Officer, 

Or send us a message via the app or email:  

If you would like a copy of how the Fraud Prevention Agencies, or our suppliers, use your information then please send us a message and we will arrange for a copy to be sent to you. 

If you would like to know what information they have about you, we can give you names of the agencies and suppliers we use.  

If you no longer wish to receive marketing about our products and services then please let us know via the App or email  


Motor Insurance Database  


Information relating to your policy will be added to the Motor Insurance Database (MID) managed by the Motor Insurers’ Bureau (MIB). The MID and the data stored on it may be used by certain statutory and/or authorised bodies including the Police, the DVLA, the DVANI, the Insurance Fraud Bureau and other bodies permitted by law for purposes not limited to but including:  

  • Electronic Licensing (Tax Discs),  

  • Continuous Insurance Enforcement,  

  • Law enforcement (prevention, detection, apprehension and/or prosecution of offenders),  

  • The provision of government services and/or other services aimed at reducing the level and incidence of uninsured driving.  


If you are involved in a road traffic accident (either in the UK, the EEA or certain other territories), insurers and/or the MIB may search the MID to obtain relevant information. 


Persons (including his or her appointed representatives) pursuing a claim in respect of a road traffic accident (including citizens of other countries) may also obtain relevant information which is held on the MID. 

It is essential that the MID holds your correct registration number. It is our responsibility to update your policy to the MID. We fully comply with the agreements in place with the MIB to update your details within seven days; however it is important that you check your policy documents ensuring that the registration number is recorded correctly.   

If it is incorrectly shown on the MID you are at risk of having your car seized by the Police. You can check that your correct registration number is shown on the MID at  

If the registration number is not shown correctly on your policy documents, or you cannot find your car on the MID, please contact us immediately. 


This policy was last updated on 1st January 2021