Privacy Policy 

 

Introduction 

Your privacy is important to us, so we have prepared this Privacy Policy to: 

 

  • Explain your privacy rights 

  • Outline how the law protects you 

  • Set out how Kudo looks after your personal data 

 

Please refer to the sections below to easily find what you are looking for: 

 

  • Who we are 

  • The data we collect 

  • How personal data is collected 

  • How and why we user personal data 

  • Who we share data with 

  • Disclosures of personal data 

  • International transfers 

  • Data security 

  • Data retention 

  • Your legal rights 

 

Who we are 

Kudo is a trading name of Toggle Data Services Limited.

 

Purpose of this privacy notice 

This privacy notice gives you information on how Kudo collects and processes your personal data through your use of our website, app, and any related services. This includes any personal data you may provide through this website and the Kudo app. 

  

It is important that you read this privacy notice together with any other notices we may provide, such as our Terms & Conditions and our Cookie Policy, so that you are fully aware of how and why we use your data. This Privacy notice does not override our other notices and may be updated from time to time. To ensure you’re kept up to date, you should re-visit this policy from regularly. 

  

Data Controller

Kudo control, and are responsible for, the personal data that we hold about you. 

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If you have any questions about this Privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.   

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We would appreciate the opportunity to deal with any data protection concerns you may have before you approach the Information Commissioner's Office (ICO) so please contact us at (dpo@kudoinsurance.com) in the first instance.  

  

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 

 

Changes to the privacy notice and your duty to inform us of changes 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

  

Third-party links  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

  

The data we collect 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

  

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: 

  

  • Identity Data includes first name, last name, username or similar identifier (including your facial features if you provide them to us in a photograph). 

  • Contact Data includes phone number, addresses, email address and telephone numbers. 

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 

  • Technical Data includes details of visits to our site, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 

  • Driving Data includes your location, speed, acceleration/ deceleration, direction of travel, date, and time. 

  • Profile Data includes your username and password, purchases or orders made by you, marketing preferences, feedback, communications you’ve sent to us or we’ve sent to you, and survey responses.    

  • Usage Data includes information about how you use our website, communications (including email and social media), products and services.   

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

  

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. 

 

We do not collect special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about non-motoring convictions and offences. In some circumstances, we may inadvertently record other special categories of personal data if this voluntarily disclosed to us in email, via chat, or over the phone. Under such circumstances, any special categories of personal data will be treated in accordance with your rights. 

 

If you fail to provide personal data: 

 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.   

How is personal data collected? 

We use different methods to collect data from and about you including through: 

  

  • Direct correspondence. You may give us your identity, contact and/or financial data by filling in forms or by contacting us via social media, our website, post, phone, text, email or otherwise. This includes personal data you provide when you: 

  • Complete our sign-up questions   

  • Create or start creating a user account on our app 

  • Provide details of any changes to your account that you may notify us of from time to time 

  • Subscribe to our service 

  • Request marketing to be sent to you 

  • Subscribe to a promotion or survey 

  • Communicate with us, whether it’s giving us some feedback, asking us any questions or providing us with any suggestions about our products and services 

  • Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details. 

  • Third parties or publicly available sources. We may receive personal data about you from various third parties including technical data from the following parties: 

(a) analytics providers 

(b) advertising networks 

(c) search information providers 

How and why we use personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

  

  • Where we need to in order to perform the contract we are about to enter into or, have entered into, with you. 

  • Where it is in our legitimate interests (or those of a third party) and your interests do not override that interest. 

  • Where we need to comply with a legal or regulatory obligation. 

  

We do not generally rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message from us. You have the right to withdraw consent to marketing at any time by visiting our communication preference centre or by contacting us. 

  

The points below set out how we use your data and the lawful basis for doing so.   

Activity: 

  

To register you as a user of the app 

Identity; Contact; Social platform permission; App location services permissions; App health permissions 

To allow the Kudo Challenge 

Device location; App health; Driving activity 

To allow us to contact you 

Contact 

To allow us to award a prize 

Contact 

To allow us to provide you with an insurance quote 

Identity; Contact; Vehicle; Non-motoring Claims & Convictions; Additional driver details; Occupation and wealth 

To allow you to purchase an insurance policy 

Identity; Contact; Vehicle; Non-motoring Claims & Convictions; Additional driver details; Occupation and wealth 

Performance of a contract with you 

Identity; Contact; Vehicle; Non-motoring Claims & Convictions; Additional driver details; Occupation and wealth 

Managing payments, fees and charges; Collecting and recovering money owed to us 

Data required: Identity; Contact; Financial; Transaction; Marketing and Communications 

 

Performance of a contract with you; Necessary for our legitimate interests (to recover debts due to us) 

Data required: Identity; Contact; Financial; Transaction; Marketing and Communications 

Notifying you about changes to our Terms & Conditions or Privacy Policy; Asking you to leave a review or take a survey 

Identity; Contact; Profile; Marketing and Communications 

 

Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) 

Identity; Contact; Vehicle; Non-motoring Claims & Convictions; Additional driver details; Occupation and wealth  

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

Identity; Contact; Technical 

 

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation 

Identity; Contact; Vehicle; Non-motoring Claims & Convictions; Additional driver details; Occupation and wealth

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you 

Identity; Contact; Profile; Usage; Marketing and Communications; Technical 

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 

Identity; Contact; Vehicle; Non-motoring Claims & Convictions; Additional driver details; Occupation and wealth  

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences 

Technical; Usage 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 

Identity; Contact; Vehicle; Non-motoring Claims & Convictions; Additional driver details; Occupation and wealth; Technical; Usage 

To make suggestions and recommendations to you about goods or services that may be of interest to you on the basis of previous sales to you via electronic means (telephone, email, SMS or App push notifications) 

Identity; Contact; Technical; Usage; Profile 

  

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list above. For the most part, we’ll be using your data to fulfil our contract with you. In providing any peripheral services, we will only use your data where it is in our legitimate interests, such as improving our goods/services, which we hope will benefit you. 

 

Marketing 

We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a communication preferences centre within your account area where you can view and make certain decisions about how we communicate with you. 

 

Promotional offers 

We may use your identity, contact, technical, usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. 

 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you started our signup process and, in each case, you have not opted out of receiving that marketing. 

  

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any company outside the Kudo group of companies for marketing purposes.   

  

Opting out 

We have established a communication preferences centre within your account area where you can view and make certain decisions about how we communicate with you (You can ask us to stop sending you marketing messages at any time by logging into the app, or by following the unsubscribe links on any marketing message sent to you via email or by contacting us at any time. 

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase. We will continue to communicate with you for reasons essential to the fulfilment of any orders (this includes information relating to your account and deliveries), you cannot opt out of any such messages. 

  

Cookies 

For more information about the cookies we use, please see our Cookie Policy. 

  

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

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If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

  

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

 

Disclosures of personal data 

 

We may share your personal information, or that of additional drivers, with: 

  • Our data enrichment provider LexisNexis (https://risk.lexisnexis.co.uk/privacy-policy). We share information concerning your request for a quote and your insurance policy with LexisNexis 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 risk.lexisnexis.co.uk/consumer-and-data-access-policies/insurance

  • Our insurance policy administration provider Instanda (https://instanda.com/privacy-policy/).  

  • Our telematics provider https://www.autoliv.com. We share your email address for the purpose of registration with their service, plus details of driving behaviour for all people named on the policy, including location and motion. 

  • Our credit reference agency – see http://www.doorda.com/ 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 

  • Our Claims provider Innovation Group (https://www.innovation.group/legal/privacy-policy/)  

  • Our Premium Finance provider PremFina (https://premfina.com/cookies-and-privacy-policy/) for the purpose of the provision and administration of our premium finance (payment by instalments) facility 

  • Our email delivery platform MailChimp (https://mailchimp.com/legal/)   

  • With suppliers acting on our behalf, for example, our insurance policy administrator (Instanda), our claims supplier (Intelligent Group), loss adjustors, solicitors, private investigators, vehicle repairers, and car hire providers 

  • 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 (https://www.intercom.com/legal/privacy) . 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. As a data processor acting on our behalf, Intercom analyses your use of our website and/or app and tracks our relationship by way of cookies and similar technologies so that we can improve our service. For more information on Intercom’s use of cookies, please visit intercom.com. We may also use Intercom as a medium for communications, either through email, push notifications, or through messages within our app. As part of our service agreements, Intercom collects publicly available contact and social information related to you to enhance your experience. Intercom’s services are governed by Intercom’s terms of use which can be found at intercom.com. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us at dpo@kudoinsurance.com  

  • 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 reinsurer(s) and brokers of reinsurers in connection with the operation of our business 

  • We will disclose information collected by the Kudo app and Autoliv in the following circumstances: 

  • 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. 

We may sell, transfer or merge parts of our business or assets. We may also seek to acquire other businesses or merge with them. During this process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private and used in the same way as explained within this privacy notice.  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third parties to process your personal data for specified purposes and in accordance with our instructions. Third-parties may contact you directly in connection to the provision of our goods/services e.g. relating to the delivery of your orders – such communications may include satisfaction surveys relating to your delivery. These communications will be covered by the third party’s privacy policy. 

  

International transfers 

Some of our servers and processors are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. 

  

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

  

  • That that country has been deemed to provide an adequate level of protection for personal data by the European Commission. 

  • We use model clauses approved by the European Commission which give personal data the same protection it has in Europe.   

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.   

  

Please contact us at dpo@kudoinsurance.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

 

Data retention 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.   

  

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

  

In some circumstances you can ask us to delete your data: see 'Request erasure' below for further information. 

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For Personal Data that is not required to be kept for legal purposes or where our legitimate interest is not overridden by your interests or fundamental rights and freedoms, we will retain your data for 24 months from the point at which you cancel your subscriptions with us and stop all interaction with Kudo. If you don’t complete our signup process for your first delivery, we will retain any Personal Data that you provide during the signup process for 12 months. If you have opted into receiving marketing messages from us, we will notify you via email prior to deleting your Personal Data so you have a chance to prevent the deletion and enable you to retain access to your account, your order profile and any correspondence with us. 

  

If you have opted out of marketing, please be aware that we will delete your Personal Data in accordance with the timeframes above without further notification to you. 

  

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

 

Your legal rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data, these include:   

  

  • Request access to your personal data. 

  • Request correction of your personal data. 

  • Request erasure of your personal data. 

  • Object to processing of your personal data. 

  • Request restriction of processing your personal data. 

  • Request transfer of your personal data. 

  • Right to withdraw consent. 

  

If you wish to exercise any of the rights set out above, please contact us at .  

  

You have the right to: 

  

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

  

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

  

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.   

  

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

  

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.   

  

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.   

  

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

  

No fee usually required 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

  

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

  

Time limit to respond 

We aim to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

 

This document was last updated on 1st February 2021