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Privacy Policy 

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

 

Who we are  

We are Kudo, which is a trading style of Blagrove Underwriting Agency Ltd; we are a data controller of the personal data we process about you for the purposes of this insurance.

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We will share data relating to your policy with Blagrove Underwriting Agency Ltd (BUA) who will also be a separate data controller of your data. You can read further about how BUA processes your data by reading their privacy notice at https://www.blagrove.com/privacy. We will also share data relating to your policy with Accredited Insurance (Europe) Limited - UK Branch.

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Your personal data and how we use it 

The table below details the personal data we process about you, what we use it for, the source and the lawful basis under data protection laws that we rely on for that use:  

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Data
Source
Purpose
Lawful basis
Cookie data
From you when you use the app.
To provide and maintain our website; to enable marketing communications. For more details see our cookie consent tool on our website which provides details of the cookies we use and the purpose.
This is necessary to provide the contracted services to you and to provide and administer insurance.
App usage analytics
From you when you use the app.
To maintain and improve the services.
This is necessary to provide the contracted services to you and to provide and administer insurance.
Contact details
From you, and select third parties (such as credit reference agencies.
To provide various marketing communications.
Legitimate interests in managing and detecting fraud.
Your personal data, including your name, address, and financial history
From you, and from select third parties (such as the Motor Insurers Bureau).
Fraud detection and risk assessment as explained in more detail below.
Public interest for the purposes of the contract of insurance.
Claims and policy amendments you have made, correspondence and engagement with us
Through the use of our app, and your smarthone’s GPS and health (movement) sensors
To provide the services.
This is necessary to provide the contracted services to you and to provide and administer insurance.
Special category data (such as health data) and criminal offence data
Through your use of the services.
To assess and provide insurance and run background checks.
This is necessary to provide the contracted services to you and to provide and administer insurance.
Movement data, including speed, time, and location
From you, and from select third parties (such as the Motor Insurers Bureau).
To provide you with an insurance quote
This is necessary to provide the contracted services to you and to provide and administer insurance.
Your insurance history, including data relevant to claims you have previously made, and insurance you have previously held
If a named driver is added to a policy, their data may be given to us by the main policyholder.
To provide the services and run background checks.
If a named driver is added, we may ask for confirmation of consent that they agree to be added.
Registration data including name and contact details
You provide this to us when you register.
To provide the services and correspond with you.
This is necessary to provide the contracted services to you and to provide and administer insurance.

Who we share your data with  

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

 

These companies and databases are:  

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  • Third-party organisations we may get data from, or who we may share data 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/)  

  • With suppliers acting on our behalf, for example, our insurance policy administrator (Instanda), our claims supplier (Innovation 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 data 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 reinsurer(s) and brokers of reinsurers in connection with the operation of our business 

  • We will disclose data 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 data, 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.

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Further details on these databases can be found at: https://www.innovation.group/legal/privacy-policy/,  https://www.mib.org.uk/managing-insurance-data/mib-managed-services/cue-miaftr/, https://www.mib.org.uk/managing-insurance-data/mib-hub/ncd/) 

 

We may also share your data with suppliers who need to process it in order to provide services to us. Where we use such suppliers, we require that enter into appropriate contracts with us committing to protect your data.  

 

Where your data is held and transferred to 

We hold your personal data on UK servers. Sometimes we may use suppliers who are based outside of the UK and/or European Economic Area. If this is the case, then we ensure that appropriate safeguards are put In place to facilitate the transfer In accordace with data protection laws. Typically such contracts will Include standard contractual clauses approved by the UK and European regulators. 

 

Fraud and money laundering  

In order to prevent and detect fraud, as explained above, 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.  

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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.  

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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: 

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  • 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 privacy policy. Please be aware however, that not all rights are absolute and may be limited in scope depending on the circumstances and the nature of your request. 

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  • 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 have the right to request that we delete the personal data we hold about you.  

  • 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. This is often known as a right of restriction. 

  • You have the right to object to us processing certain personal data about you in some circumstances. For example, you can ask us to stop processing your data for direct marketing purposes. You can unsubscribe from direct marketing using the unsubscribe link in emails or sending STOP in response to a marketing SMS. You can also disable certain communications, like push notifications, in our app or your device’s settings. 

  • 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. 

  • You have the right to raise a complaint with the Information Commissioner's Office. 

 

If we change something  

Sometimes we may need to change the way we use your data. 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:  

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Data Protection Officer, dpo@kudoinsurance.com 

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Or send us a message via the app or email: dpo@kudoinsurance.com  

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

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

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If you no longer wish to receive direct marketing about our products and services then please let us know via the App or email help@kudoinsurance.com .

 

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:  

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  • 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.  

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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 data. 

  

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 data which is held on the MID. 

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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 www.askMID.com.  

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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 the 6th April 2022 

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